The RWE Alliance envisions a future in which data generated in everyday clinical practice through electronic health records, administrative claims and billing data, product and disease registries, personal devices, wearables, and health applications will be used to generate evidence that complements clinical trials.
To achieve this goal, we advocate for policies that will:
We support FDA’s ongoing work to facilitate the use of real-world data (RWD) and real-world evidence (RWE), which will add to the understanding of medical product safety and effectiveness and benefit patients.
FDA and Congress have taken important steps to advance the use of RWD/E. The 21st Century Cures Act contains an important provision that calls on FDA to publish a framework for the use of RWE for regulatory purposes, and FDA has taken steps to implement this provision by publishing a draft framework in December 2018 and issuing valuable guidance.
As real-world data and analytics organizations with a common interest in harnessing the power of RWE, we stand ready to provide partnership, expertise, and perspective as the Agency develops RWD/E guidance and policy, and as Congress considers action in this space. We believe that fit-for-purpose RWE can play an important role in the review of medical products—and can provide or contribute to substantial evidence of effectiveness. We believe that additional FDA guidance and policies regarding various applications of RWE, including its use in creating external comparator arms (ECAs), assessing fit-for-use data, and establishing real-world endpoints, will be helpful. We aim to contribute to the Agency’s efforts to further clarify topics such as:
These efforts will build on FDA’s existing RWE Framework and advance the use of RWE to ultimately benefit patients. The RWE Alliance will work to promote utilization of RWE across therapeutic areas, not only within oncology and rare diseases where there are published examples of the use of RWE. To ensure RWE analyses are clinically meaningful and can be used in regulatory decision making, we recommend that regulatory guidelines for RWE communicate clear expectations for using RWD, for generating RWE, and for FDA’s evaluation of RWE. At the same time, given the rapid advancement of the RWE field, we believe it is critical that regulatory guidance remain flexible to accommodate advancements in data, methods, and technology.
RWE can play a role in providing FDA, patients, healthcare providers, and other stakeholders with information on treatment effects among underrepresented populations across therapeutic areas. Clinical trial study populations frequently are not fully representative of relevant patient populations in real-world settings. We will work to support the use of RWE as a resource to help address disparities in healthcare access, treatment, and outcomes.
We seek and support increased opportunities for RWE organizations to consult with FDA on specific topics relevant to the potential uses of RWE for regulatory decision making across therapeutic areas.
Medical product sponsors and RWE organizations benefit greatly from FDA’s feedback. We will work to provide summary information and insights from our collective industry efforts to FDA. We will also work with FDA and other stakeholders to establish mechanisms and opportunities for RWE organizations to engage on RWE methods and applications.
Communication of FDA’s review of RWE in marketing applications is crucial to advancing best practices in the use of RWE for regulatory purposes and to ensuring a widespread understanding of the benefits that RWE ultimately delivers to patients.
To increase this communication, we support FDA raising broader awareness about current and potential uses for RWE. We also support FDA providing more detailed guidance on how RWE should be presented in submission packages and product labeling, as well as FDA making public a summary of the Agency’s review of RWE when included in original or supplemental applications.