by Giuliana Miglierini
Digitalisation is rapidly advancing also in the regulatory field, as a tool to improve the efficiency and accuracy of processes used for the generation and use of data to inform the regulatory decision-making. To this instance, real-world data (RWD) on the use of a certain medicine by the general population are increasingly important to monitor the impact in terms of health benefits, adverse events and costs for healthcare systems.
The trend is confirmed by the publication of a joint statement by the International Coalition of Medicines Regulatory Authorities (ICMRA) addressing the use of real-world data and real-world evidence (RWE) in the development, authorisation and monitoring of medicines to support regulatory decision-making. The document has been endorsed by the European Medicines Agency (EMA), which also published the third workplan developed by its Big Data Steering Group to set key actions to be delivered in the period 2022–2025.
The debate on real-world evidence for regulatory decision making was also stimulated by an ISPE’s position paper released in 2020, and by papers published in the scientific literature (see here a recent review).
ICMRA’s joint statement on real-world evidence
The joint statement is the final result of a ICMRA workshop on real-world evidence co-organised with EMA, the US FDA and Health Canada in June 2022, that saw the participation of representatives from more than 40 countries. Heterogeneous data sources across different geographic areas and different levels of quality, as well as various processes for data sharing and access of the data, were among the main open issues identified during the meeting. Four different areas of collaboration have been identified, representing the focus of further discussion by international regulators in order to implement concrete actions to address criticalities.
The first area addresses the harmonisation of RWD and RWE terminologies. This exercise is deemed essential in order to share common operational definitions of RWD and RWE, characterized by a clear scope and level of granularity (e.g., pertaining to RCTs and observational studies).
Already existing guidance, such as the ICH M14 on “General principles on planning and designing pharmacoepidemiological studies that utilize real-world data for safety assessment of a medicine”, may represent useful tools to support these activities.
The convergence on RWD and RWE guidance and best practice should include the development of common principles for RWD quality. Metadata are an essential feature, as they enable the characterisation and discoverability of RWD. Other targets include the definition of suitable scenarios where RWE may contribute to regulatory decision-making, and the setting up of templates for study protocols/reports that can be used in multiple regulatory jurisdictions.
Readiness shall be pursued by strengthening the international regulatory collaboration on RWE. The rapid creation of expert groups on specific topics of interest and an improved collaboration on governance and processes aimed to support the efficient conduct of RWD studies in different countries are key actions in this area.
Transparency should be the common denominator underlying all the above-mentioned activities. It should be tackled through the definition and use of common principles and practices for the systematic registration of pre-specified study protocols and study results in publicly available registries. Publication of study results in open-source, peer-reviewed journals is also expected.
The 2022-2025 workplan on Big Data use for public health
In parallel with the publication of ICMRA’s joint statement, EMA released the Big Data Workplan 2022-2025, jointly developed with the Heads of Medicines Agencies (HMA). The joint workplan represents the expansion towards the operative phase of the priority recommendations for regulators on the best approaches to use and generate data developed in 2020 by the former Big Data Task Force. The document refers mainly to medicines for human use, even if it includes some information on veterinary medicines.
Big data are the key element to be considered in order to achieve the overall objectives seen above, as they enable the extensive analysis of information available on medicinal products subject to regulatory scrutiny. According to the Big Data Steering Group, the increased evidence arising from big data analysis may accelerate medicine development, improve treatment outcomes and facilitate earlier patient access to new treatments.
The workplan details ten different priory areas and the respective recommendations for action, and it provides the expected timelines for their implementation.
Central to the overall planned system is the Data Analysis and Real-World Interrogation Network (DARWIN EU), a federated network to enable access and analysis of real-world data. After the establishment of the DARWIN EU Coordination Centre and the activation of the first studies in 2022, new activities shall focus on the support to the European Health Data Space (EHDS) and the collaboration with the European Centre for Disease Prevention and Control (ECDC), HTA bodies and payers.
The joint action Towards A European Health Data Space (TEHDAS) shall facilitate the engagement with stakeholders, a critical point to ensure the quality of data. The release of a first version of a data quality framework for the EU Regulatory Network is expected in late 2022. An agreement on metadata to describe and identify RWD sets shall also be supported by the publication of a good practice guide on metadata and a public catalogue of European RWD. Release of new analytics tools and a review of the utility of eHealth data and social media data are also part of actions targeted to data discoverability.
The reinforcement of skills of all stakeholders involved in the process of RWD and RWE generation, analysis and use is also essential to guarantee the success of the new approach. EMA and HMA aim to develop agreed training curricula on biostatistics, pharmacoepidemiology and data science, including the availability of selected modules open to patients, healthcare professionals and academics. A curriculum on genomics data shall also be adopted.
The results of pilot studies on the use of RWE by EMA scientific committees will be released in next years, with a final report and a portfolio of RWE use cases to support uptake of RWE by the ERMN expected in 2025.
More in detail, a proof-of-concept pilot assessing access to individual patient data from clinical trials (raw data) in the scientific assessment of medicines is planned for Q4 2022. The final reflection paper on artificial intelligence (AI) for use in regulatory processes shall be published in Q3 2023, while 2024 should focus on a pilot on data analysis for CMC data.
All the above-mentioned activities shall be supported by new guidance issued by the new EMA Methodologies Working Party, while expert advice will be strengthened through the European Specialised Expert Communities (ESEC), initially focusing on AI & RWE.
The governance of the process shall benefit by a review of the mandates of the Big Date Steering Group and EU Network Data Board expected for late 2022. Target actions aimed to strengthen the framework for ethics in data analysis will also be explored. Activities at the level of the international framework of regulators shall include among others the evaluation of the clinical trial conceptual model under the ICH M11.
An annual Big Data stakeholder forum is also planned, complemented by topic specific meetings and workshops and biannual industry meetings. In the veterinary field, the workplan includes the implementation of the EU Veterinary Big Data strategy adopted in 2022. Among the main deliverable are a catalogue of veterinary data sources, finalisation of the system on antimicrobials sale and use data, and the evolution of training curricula.
EDQM introduces a consultation phase in the management of CEP documents
by Giuliana Miglierini
The new process implemented by the European Directorate for the Quality of Medicines and HealthCare (EDQM) for the elaboration of documents related to the Certification of Suitability (CEP) procedure includes a newly inserted consultation phase. This new step, which may be public or targeted to specific groups of stakeholders, aims to increase the transparency of the elaboration process and offers stakeholders the possibility to forward comments to the draft documents in order to optimise them.
Transparency and efficiency are also the main goals inspiring the overall new elaboration process, which covers the entire pathway of CEP documents, from development, through consultation, up to final adoption, publication and implementation.
A dedicated page on the EDQMs’s website will host the documents open to consultation, together with the respective instructions for the stakeholders wishing to submit comments. Announcements on new documents available for consultation will be made on EDQM Certification webpages. The CEP Steering Committee will be responsible for the elaboration process for CEP documents, in compliance with the EDQM document CEP Terms of Reference and Rules of Procedure (PA/PH/CEP (01) 1).
The elaboration process will cover both public documents (the main part), as well as those the CEP Steering Committee would indicate as restricted for use by the bodies involved in the CEP procedure. The new process does not cover the Resolution on the Certification procedure, which falls under another specific process established by the Council of Europe.
A guidance to understand the new process
The management of CEP guidelines and operational documents for the CEP procedure has been described in a specific guidance issued in November 2022 by the EDQM’s Certification of Substances Department.
The guidance covers a broad range of documents participating from different perspectives to the CEP procedure. The elaboration of the different types of documents may slightly differ from one another, with possible exemptions from some steps, for example in the case of minor revisions (which in any case always have to be full justified and documented). All CEP documents will be drafted in English; the guidance provides indication of the format to be used to establish the unique reference code for governance documents and technical guidelines (PA/PH/CEP (XX) YY), as well as for the revision number (ZR) where needed.
The EDQM specifies that the implementation date of the newly approved CEP documents will be such to allow interested parties to have enough time to comply with the new or revised requirements.
Governance documents define procedural aspects for the practical implementation of the CEP procedure. The initial draft will be prepared by the EDQM and reviewed and agreed upon by the CEP Steering Committee before entering the consultation phase. Comments collected will serve as the basis to consolidate the final version of the document. A second round of consultation may be needed in case of critical comments preventing finalisation. The adoption of the final document falls under the responsibility of the CEP Steering Committee, which may also indicate the need to improve and re-submit the draft before adoption. Once the final version of the document is available, its publication on the EDQM’s website and implementation will close the process.
Technical guidelines inform about the requirements applicants should fulfil for the submission or evaluation of CEP applications. Their drafting may be initiated also by members of the relevant Technical Advisory Board (TAB), in addition to the EDQM. The TAB is also called to review and agree upon the draft document before the assessment and approval by the CEP Steering Committee and the following consultation phase can take place. The same applies to the consolidation of comments and finalisation of the document, that has to be approved by the relevant TAB. In this case too, a second round of consultation is possible should criticalities arise during the first one, followed by adoption by the CEP Steering Committee (and a possible second round of updating and approval by the TAB, if needed), and publication and implementation.
The management of specific aspects of the procedure can be supported by the issuing of administrative or operational documents. These documents fall under the responsibility of the EDQM, that may consult the CEP Steering Committee of other parties where necessary.
The consultation phase
A specific chapter of the EDQM’s guidance describes the newly inserted consultation phase, those details (type of process and duration) will be decided on a case-by-case basis by the CEP Steering Committee.
In the case of a public consultation, the draft document will be made available at the dedicated page of the EDQM website. The draft may also be sent to identified relevant stakeholder organisations, to ensure a better awareness of the ongoing process.
Targeted consultations aim to obtain feedback from selected stakeholders on specific areas of intervention. In such instances, the forwarding of the draft document will be restricted only to identified interested parties, including regulators and relevant industrial associations or other organisations.
According to the type of document and/or the topic under consultation, the consultation phase may vary in duration. To this instance, the guidance indicates a possible range between 3 weeks and 3 months, with the effective duration to be communicated as a part of the call for consultation. A template will also be available to submit comments, which should be always justified and contain concrete proposals for action to tackle the issue under consideration. All comments and justifications received will be transmitted to the groups in charge of approving and adopting the documents.
At the end of the elaboration process, the final approved versions of CEP documents will be published on the EDQM’s website.