Good Practices for Real‐World Data Studies of Treatment And/Or

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Good Practices for Real‐World Data Studies of Treatment And/Or VALUE IN HEALTH 20 (2017) 1003– 1008 Available online at www.sciencedirect.com journal homepage: www.elsevier.com/locate/jval Original Report Good Practices for Real‐World Data Studies of Treatment and/or Comparative Effectiveness: Recommendations from the Joint ISPOR‐ISPE Special Task Force on Real‐World Evidence in Health Care Decision Making à Marc L. Berger1, , Harold Sox2, Richard J. Willke3, Diana L. Brixner4, Hans‐Georg Eichler5, Wim Goettsch6, David Madigan7, Amr Makady6, Sebastian Schneeweiss8, Rosanna Tarricone9, Shirley V. Wang8, John Watkins10, C. Daniel Mullins11 1New York City, NY, USA; 2Patient-Centered Outcomes Research Institute, Washington, DC, USA; 3International Society for Pharmacoeconomics and Outcomes Research, Lawrenceville, NJ, USA; 4University of Utah, Salt Lake City, UT, USA; 5European Medicines Agency, London, UK; 6Zorginstituut Nederland and University of Utrecht, Utrecht, The Netherlands; 7Columbia University, New York City, NY, USA; 8Brigham and Women's Hospital, Harvard Medical School, Boston, MA, USA; 9Bocconi University, Milan, Italy; 10Premera Blue Cross, Mountlake Terrace, WA, USA; 11University of Maryland, Baltimore, MD, USA ABSTRACT Purpose: Real‐world evidence (RWE) includes data from retrospective involvement in RWE studies. These recommendations, in concert with or prospective observational studies and observational registries and earlier recommendations about study methodology, provide a trust- provides insights beyond those addressed by randomized controlled worthy foundation for the expanded use of RWE in health care decision trials. RWE studies aim to improve health care decision making. making. Conclusion: The focus of these recommendations is good Methods: The International Society for Pharmacoeconomics and Out- procedural practices for studies that test a specifichypothesisina comes Research (ISPOR) and the International Society for Pharmacoepi- specific population. We recognize that some of the recommendations in demiology (ISPE) created a task force to make recommendations this report may not be widely adopted without appropriate incentives regarding good procedural practices that would enhance decision from decision makers, journal editors, and other key stakeholders. makers’ confidence in evidence derived from RWD studies. Peer review Keywords: comparative effectiveness, decision making, guidelines, by ISPOR/ISPE members and task force participants provided a consen- pharmacoepidemiology, real‐world data, treatment effectiveness. sus‐building iterative process for the topics and framing of recommen- dations. Results: The ISPOR/ISPE Task Force recommendations cover & 2017 Published by Elsevier Inc. on behalf of International Society for seventopicssuchasstudyregistration, replicability, and stakeholder Pharmacoeconomics and Outcomes Research (ISPOR). Introduction and interpreted accordingly, whereas data is but one component of the research plan. Evidence is shaped, while data simply are Real‐world evidence (RWE) is obtained from analyzing real‐world raw materials and alone are non‐informative.” RWE can inform data (RWD). The RWD is defined here briefly as data obtained the application of evidence from RCTs to health care decision outside the context of randomized controlled trials (RCTs) gen- making and provide insights beyond those addressed by RCTs. erated during routine clinical practice [1,2]. This includes data RWD studies assess both the care and health outcomes of from retrospective or prospective observational studies and patients in routine clinical practice and produce RWE. In contrast observational registries; some consider data from single arm to RCTs, patients and their clinicians choose treatments on the clinical trials as RWD. As stated in a 2007 International Society basis of the patient's clinical characteristics and preferences. for Pharmacoeconomics and Outcomes Research (ISPOR) task However, since the factors that influence treatment choice in force report, “Evidence is generated according to a research plan clinical practice may also influence clinical outcomes, RWD Marc L. Berger is a self‐employed part‐time consultant. This article is a joint publication by Pharmacoepidemiology and Drug Safety and Value in Health. * Address correspondence to: Marc L. Berger, New York, NY, USA. E-mail: [email protected] 1098-3015$36.00 – see front matter & 2017 Published by Elsevier Inc. on behalf of International Society for Pharmacoeconomics and Outcomes Research (ISPOR). http://dx.doi.org/10.1016/j.jval.2017.08.3019 1004 VALUE IN HEALTH 20 (2017) 1003– 1008 studies generally cannot yield definitive causal conclusions about We recognize that procedural integrity is necessary but not the effects of treatment. sufficient for including RWD studies in the body of evidence that Currently, most regulatory bodies and Health Technology health policy makers use to make a decision. Other factors play a Assessment (HTA) organizations use RWE for descriptive analyses role, including the study design, adjudication of outcomes (eg, disease epidemiology, treatment patterns, and burden of illness) (if relevant), transparency and methodological rigor of the and to assess treatment safety (the incidence of adverse effects) but analyses, and size of the treatment effect among others. None- not treatment effectiveness, whereas other decision makers also theless, the focus of this report is the role of procedural practices leverage RWD to varying extents with respect to effectiveness and that enhance the trustworthiness of the larger process, with a compartive effectiveness [3]. With increasing attention paid to the particular focus on the effectiveness or comparative effectiveness applicability of evidence to specific target populations, however, of pharmaceutical and biologic treatments. clinicians, payers, HTA organizations, regulators, and clinical guide- The scope of this report does not, by design, directly address linedevelopersarelikelytoturntoRWEtosharpendecisionmaking several important considerations when RWD studies are that heretofore had been guided principally by RCTs (frequently reviewed by decision makers: using a placebo control) in narrowly defined populations. Commonly voiced concerns about RWD studies include uncer- • Good practices for the design, analysis, and reporting of tainty about their internal validity, inaccurate recording of health observational RWD studies (ie, methodological standards). events, missing data, and opaque reporting of conduct and results These issues have been addressed by ISPOR, ISPE, the US Food [4]. Critics of such studies also worry that the RWE literature is and Drug Administration (FDA), the European Medicines biased because of “data dredging” (ie, conducting multiple analyses Agency, the European Network of Centres for Pharmacoepi- until one provides the hoped‐for result) and selective publication demiology and Pharmacovigilance (ENCePP®), and the Euro- (ie, journals' preference for publishing positive results) [5–8].Asa pean Network for Health Technology Assessment [11–23]. Their first step toward addressing these concerns, the ISPOR and the recommendations aim to improve the validity and relevance of International Society for Pharmacoepidemiology (ISPE) created a RWD studies by adequately addressing methodological issues task force to make recommendations regarding good procedural including confounding, bias, and uncertainty, which are the practices that would enhance decision makers' confidence in explicit objections raised by payers and regulatory bodies to evidence derived from RWD studies. using RWD studies to inform decision making. We define good procedural practices (or good “study hygiene”)as • Good practices for the conduct of pragmatic clinical trials policies about the planning, execution, and dissemination of RWD (pRCTs or PCTs). pRCTs are randomized trials with varying studies that help to assure the public of the integrity of the research amounts of pragmatic (real world) elements, including the use process and enhance confidence in the RWE produced from RWD of electronic health records or claims data to obtain study studies. Journal editors and regulatory agencies have established outcomes [24]. good procedural practices for pre‐approval RCTs, including study • We take no position on whether, and in which context, policy registration of trials on a public website prior to their conduct, the makers may deem observational studies sufficiently transpar- completion of an a priori protocol and data analysis plan, account- ent to routinely support initial regulatory approval and ability for documenting any changes in study procedures, and the reimbursement. expectation that all RCT results will be made public [9,10].A statement of complementary practices for RWD studies of treat- The focus of this report is RWE examining the effectiveness of ment effectiveness is lacking. Our report aims to fill this gap. pharmaceutical or biologic therapies. Although the recommenda- We differentiate 2 categories of RWD studies aiming to tions of this report will have relevance for all types of therapeutic provide data on treatment effectiveness that may differ in their health technologies, we recognize that applying these recommen- procedural approach: dations to technologies different from drugs (ie, medical devices) might require further refinement because of differences in the • Exploratory Treatment Effectiveness Studies. These studies evidence required for regulatory approval [25]. typically do not hypothesize the presence of a specific treat-
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