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RWR Insights | Quality Standards for Registries – EUnetHTA REQUEST Tool

RWR CONTEXT

This is the third (3rd) and last in the series exploring current quality standards for registries and registry-based studies.  This month we focus on quality standard expectations when using real world data (RWD) from registries to support Health Technology Assessment.  Specifically, we’ll look in detail at the ‘Registry Evaluation and Quality Standards Tool (REQueST)’ tool developed by the European Network for Health Technology Assessment (EUnetHTA)

APRIL 2022 – This is the third (3rd) and last in the series exploring current quality standards for registries and registry-based studies.  This month we focus on quality standard expectations when using real world data (RWD) from registries to support Health Technology Assessment.  Specifically, we’ll look in detail at the ‘Registry Evaluation and Quality Standards Tool (REQueST)’ tool developed by the European Network for Health Technology Assessment (EUnetHTA) [1] [2]. 

The use of registries is becoming increasingly common in health technology assessment (HTA) and regulation. There is a growing interest in the role of observational data in complementing experimental data. This project aims to support best practice in the collection, use and re-use of real world data, and explore options to support sustainable multi-stakeholder collaboration (as per Paragraph 1 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019) [3].

EUnetHTA – REQUEST Tool 

For HTA purposes, the Registry Evaluation and Quality Standards Tool (REQueST) is designed to be used in 3 steps (as per Paragraph 13 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

    • Step 1: Initial screening of a potential registry for suitability. Standards currently presented in the ‘Methodological Information’ section of the tool are intended to enable a user to assess whether a registry can provide data that fulfil their needs6.
    • Step 2: All registries that are potentially suitable should then be assessed against ‘Essential Standards’ relating to registry quality.
    • Step 3: Some registries will require assessment against additional criteria for specific purposes (e.g., international collaboration on data collection will require interoperability). This is assessed in the ‘Additional Requirements’ section of the tool.

The registry owner carries out a self-assessment by completing the ‘registry owner’ column in the ‘Essential Standards’ worksheet of REQueST. This information together with a summary of the registry methodological information and the minimum key documents (listed in paragraph 32) are presented on the registry’s web site. These may be reviewed at any point by organisations considering whether to use the data in evidence development for HTA and regulatory monitoring to check if the information meets their needs (as per Paragraph 23 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019).

Periodic Review of Registries

In general, assessment of the quality of a registry cannot be done as a one-off event; ongoing quality needs to be demonstrated and the tool output will require periodic review (as per Paragraph 30 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019).

Criteria for the frequency of registry review could include the (as per Paragraph 30 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

    • Maturity of the registry and technology (e.g., national joint registries dealing with established technologies and governance would require less frequent review).
    • Production of peer-reviewed publications based on the registry (e.g., if at least one peer-reviewed publication per technology is produced in an acceptable time interval, the REQueST review could be less frequent).
    • Purpose of the registry (e.g., if it is bespoke, that is, to meet specific regulatory or technology assessment objectives, quality should be assessed at the beginning and at the point of data use).

It should be noted that the ‘Methodological Information’ and ‘Additional Requirements’ sections of REQueST include questions that relate to specific uses of a registry. Users of REQueST may therefore need to run the tool more than once for an individual registry, and only the ‘Essential Standards’ would be transferrable between assessments (as per Paragraph 31 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019).

All phases require the registry owner to produce and make publicly available the following ‘minimum key documents’ (as per Paragraph 32 of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

    • Registry aims and methodology including minimum data set and data security policies.
    • Declarations of relevant interests.
    • Demonstration of continuous and comprehensive data collection (exact format and periodicity to be agreed but this is likely to include regular reporting on coverage, completeness and validation of data). Where a registry is federated between many countries, a report would be required from every participating registry.
    • Safety statement detailing any alerts that have been raised (initiated by the registry owner and jointly publicised with the regulator/assessor).

Methodological Information – Screen for registries whose data and methodology match the requirements of the HTA/regulatory study or research question(s)

‘Methodological Information’ refers to the research methodology and which information is collected (research question, protocol and observational methods). This section provides an opportunity for the HTA agency to gather information about the data collected by the registry. Methodological information will be used to assess whether a registry is ready and able to answer a specific research question. There are 8 ‘Methodological Information’ items covering the following areas (as per Appendix A of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

•      Type of registry

•      Use for registry-based studies and previous publications

•      Geographical and organisational setting

•      Duration

•      Size

•      Inclusion and exclusion criteria

•      Follow-up

•      Confounders

Essential Standards – Assessment of registry governance to assure general data quality and protection

‘Essential Standards’ are the minimum requirements for every registry. They are essential elements of good practice and evidence quality that can be used in the evaluation of the registry. Unless all essential criteria are demonstrably fulfilled, the HTA agency should not use the registry for evidence evaluation. There are 12 ‘Essential Standards’ items covering the following areas (as per Appendix A of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

1.     Registry aims and methodology

2.     Governance

3.     Informed consent

4.     Data dictionary

5.     Minimum data set

6.     Standard definitions, terminology and specifications

7.     Data collection

8.     Quality assurance

9.     Data cleaning

10.  Missing data

11.  Financing

12.  Protection, security and safeguards

Additional Requirements – Specific requirements for the evidence questions

‘Additional Requirements’ are elements of good practice and evidence quality which are not always practical or feasible to achieve but are useful to consider in planning and evaluating registries. Evaluation of the ‘Additional Requirements’ depends on the requirements of an individual HTA agency and the specific context or registry use (e.g., an international collaboration on data collection will require registry interoperability). There are 3 ‘Additional Requirements’ items covering the following areas (as per Appendix A of the EUnetHTA JA3 Vision Paper on REQueST Tool, September 2019):

•      Interoperability and readiness for data linkage

•      Data sources

•      Ethics

References

1. Registry Evaluation and Quality Standards Tool (REQueST)

Link: https://www.eunethta.eu/request-tool-and-its-vision-paper/ 

2. European Network for Health Technology Assessment (EUnetHTA)

Link: https://www.eunethta.eu/ 

3. EUnetHTA JA3 Vision Paper on REQueST Tool (September 2019)

Link: https://d2yaq9q3r816qg.cloudfront.net/wp-content/uploads/2019/10/EUnetHTAJA3_Vision_paper-v.0.44-for-ZIN.pdf?x69613

RWR Insights | Quality Standards for Registries – EUnetHTA REQUEST Tool2022-08-07T16:34:25+00:00

EU – Version 5 of the Questions and Answers Document for the EU Clinical Trials Regulation (Regulation EU/536/2014) has Been Published

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EU – Version 5 of the Questions and Answers Document for the EU Clinical Trials Regulation (Regulation EU/536/2014) has Been Published2022-08-07T16:51:50+00:00

Insights | EU – Quality Standards for Registry Studies

RWR CONTEXT

“Quality RWE can’t be Built without Quality RWD”

EMA checklist for evaluating the suitability of registries for registry-based studies = Data quality guideline addressing quality expectations of real world data sources (i.e., disease registries) used to generate real world evidence (RWE) for regulatory purposes

31 AUGUST 2021 – According to a recent US FDA presentation (May 2021)[1]:

“Quality RWE can’t be Built without Quality RWD”

As noted in the National Guidelines for Data Quality in Surveys[2] published in August 2021 by the ICMR-National Institute of Medical Statistics (ICMR-NIMS)[3]:

“There is an impending need…for data quality guidelines to improve the quality of data that promotes evidence-based decision making”

In September 2020, the EMA published a [draft] checklist[4] for evaluating the suitability of registries for registry-based studies. The list is adapted from the REQueST[5] tool published by EUnetHTA[6].

Why is this important?

This is one of the first quality standards [data quality guidelines] published by the EMA that specifically addresses the quality expectations of real world data sources (i.e., disease registries) used to generate real world evidence (RWE) for regulatory purposes.

According to the EMA[7], the use of a registry-based study for a regulatory purpose depends on many factors related to its relevance to answer a specific research question, the characteristics of the concerned registry, the quality of the data collected and the design and analytical plan of the proposed study.

The tool has been developed to be a comprehensive resource that covers all important aspects relating to the quality of registries. The standards set out in the tool are universal and essential elements of good practice and evidence quality that are, therefore, relevant for different types of registries.

Examples of where registry-based studies may be useful for evidence generation[7]:

  • To supplement the evidence generated in the pre-authorisation phase
  • To provide data sources or infrastructure for post-authorisation evidence generation
  • To evaluate the effects of medications received during pregnancy

Things to assess, be aware of, or consider when assessing the suitability of a patient registry for a registry-based study, include:

1. Administrative information
1.1. Governance for collaborations
– Publicly available documentation (with website) of key registry characteristics
– Single contact point for information
– Publicly available policy for collaborations with external organisations
– Governance structure for decision-making on requests for collaboration
– Supportive scientific and technical function
– Supportive function for ethical and legal aspects
– Template for research contracts between the registry and external organisations
1.2. Data privacy
– Status of implementation of GDPR
– Informed consent form and its validity for registry-based studies (or need for re-consent)
1.3. Funding
– Funding sources and impact on short, long-term sustainability and possible conflicts of interest for a specific registry-based study
2. Methods
2.1. Objectives
Purpose of the data collection system, which may influence the main characteristics of the registry population and the data collected
2.2. Data providers
– Adequate description of data providers, such as patients, carers or health care professionals (with different specialties), their geographical area and any selection process (inclusion and exclusion criteria) that may be applied for their acceptance as data providers
2.3. Patient population covered
– Adequate description of the type of patient registry (disease, condition, time period covered, procedure), which defines the criteria for patient eligibility
– Relevance of setting and catchment area
– Clarity on patients’ inclusion and exclusion criteria
– Methods applied to minimise selection bias and loss to follow-up
– Numbers of patients available in the registry (total number and number of eligible patients if applicable), numbers of new patients entering the registry per year, numbers of patients lost per year (with reasons for exit)
– Mean/median duration of follow-up per patient, person-time of exposure in defined categories, if applicable
2.4. Data elements
– Core data set collected from patients by all centres; optional data set
– Definition, dictionary and format of data elements
– Standards and terminologies applied
– Capabilities and plans for amendments of data elements
2.5. Infrastructure
– Systems for data collection, recording and reporting, including timelines
– Capability (and experience) for expedited reporting and evaluation (at physician or registry level) of severe suspected adverse reactions in primary data collection
– Capability (and experience) for periodic reporting of clinical outcomes and adverse events reported by physicians, at individual-patient level and aggregated data level
– Capability (and experience) for data cleaning, extraction, transformation and analysis
– Capability (and experience) for data transfer to external organisations
– Capabilities for amendment of safety reporting processes
2.6. Quality requirements
– Processes in place for quality planning, control, assurance and improvement
– Data verification (method and frequency of verification)
– Missing data (statistics, trends, variables affected, management)
– Auditing practice

What’s Next?

The 2021-2023 HMA-EMA joint Big Data Steering Group (BDSG) have published their ‘2021 – 2023 Workplan’.

Milestones to be aware of, include:

  • Publication of Registries Guidance (November 2021)
  • Roadmap for RWE Guidance Agreed (April 2022)
  • EMA Draft Q&A on Secondary Use of Health Care Data and Data Protection (December 2021)

References

1. The FDA Real-World Evidence (RWE) Framework and Considerations for Use in Regulatory Decision-Making. Jacqueline Corrigan-Curay, JD, MD. Meeting of the Pediatric Oncology Subcommittee of the Oncologic Drugs Advisory Committee May 12, 2021
Link: https://www.fda.gov/media/148543/download

2. ICMR-National Institute of Medical Statistics (ICMR-NIMS)
Link: http://icmr-nims.nic.in/

3. National Guidelines for Data Quality in Surveys. ICMR-National Institute of Medical Statistics, New Delhi. July 2021
Link: https://main.icmr.nic.in/sites/default/files/upload_documents/National_Guidelines_for_DATA_QUALITY_in_Surveys.pdf

4. Appendix 3 of [DRAFT] EMA Guideline on Registry-Based Studies (EMA/502388/2020) (24 September 2020)
Link: https://www.ema.europa.eu/en/documents/scientific-guideline/guideline-registry-based-studies_en.pdf

5. REQueST = Registry Evaluation and Quality Standards Tool (REQueST)
Link: https://www.eunethta.eu/request-tool-and-its-vision-paper/

6. EUnetHTA – European Network for Health Technology Assessment
Link: https://www.eunethta.eu/

7. Section 3.1 of [DRAFT] EMA Guideline on Registry-Based Studies (EMA/502388/2020) (24 September 2020)
Link: https://www.ema.europa.eu/en/documents/scientific-guideline/guideline-registry-based-studies_en.pdf

8. Section 1 of the [DRAFT] EMA Guideline on Registry-Based Studies (EMA/502388/2020) (24 September 2020)
Link: https://www.ema.europa.eu/en/documents/scientific-guideline/guideline-registry-based-studies_en.pdf

Insights | EU – Quality Standards for Registry Studies2022-08-07T17:34:59+00:00
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