Real World Evidence (RWE) 101 – Ethical Imperatives
Real-world evidence (RWE) refers to the clinical evidence regarding the usage and potential benefits or risks of a product derived from analysis of real-world data (RWD). These data are routinely collected from a variety of sources, such as electronic health records, claims and billing data, patient registries, and data gathered through personal devices. RWE is increasingly being used in clinical trials and marketing authorisations.
The ethical imperative of incorporating RWE into clinical trials intended to support marketing authorizations arises from several factors:
[1] Patient-centric Approach: RWE provides a more holistic and accurate view of the patient experience as it considers a wide range of factors such as comorbidities, patient behaviour, social determinants of health, and the full array of interventions. This allows for a patient-centric approach in medical research, which respects the dignity, rights, and welfare of individuals.
[2] Generalizability: RWE is collected from diverse patient populations and settings and can therefore inform on how a drug or intervention works in the ‘real world,’ beyond the controlled environment of randomized controlled trials (RCTs). This increases the generalizability of research findings and supports the ethical principle of justice, ensuring that the benefits of research are applicable and beneficial to all groups.
[3] Safety and Effectiveness: RWE can provide additional information on a drug’s safety and effectiveness in broader populations and over longer periods, beyond what can be feasibly assessed in RCTs. This can provide early signals of potential harm and help prevent unnecessary patient exposure to harmful interventions.
[4] Efficiency: Incorporating RWE can make research more efficient, reducing the time and cost of bringing a new product to market. This is ethically significant as it can accelerate patient access to beneficial new treatments.
[5] Informed Decision Making: RWE helps physicians, patients, and policy-makers make informed decisions. Better evidence can improve the quality of care, patient outcomes, and health system efficiency.
[6] Inclusivity: Traditional clinical trials often exclude certain patient groups, such as the elderly or those with multiple health conditions. RWE includes data from these often under-represented groups, ensuring that the findings are applicable to them.
The importance of RWE lies in its ability to provide an enhanced understanding of a drug’s safety, effectiveness, and value in routine clinical practice. It can capture the wide heterogeneity of patients, healthcare providers, and treatment settings, providing a much-needed complement to traditional RCTs. By integrating RWE into the process of marketing authorizations, regulators can make more informed decisions, ensuring that only safe and effective drugs reach the market, ultimately improving patient health outcomes.
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
stuart.mccully2023-08-09T15:27:28+00:00August 9, 2023|2023, RWE 101|
RWE 101 - ICH GCP (R3) - Real World Evidence Context Revision 2 of ICH GCP caused confusion to those of us who work with non-interventional studies. The glossary [...]
Real World Evidence (RWE) 101 – Non-Interventional Studies vs Market Health Research
stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Non-Interventional Studies vs Market Health Research Key differences between a non-interventional study (NIS) and market health research include:1. Research Objective: NIS are conducted to examine real-world [...]
Real World Evidence (RWE) 101 – Real World Evidence (RWE) 101 – Audits vs Inspections
stuart.mccully2023-08-09T14:51:12+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Real World Evidence (RWE) 101 - Audits vs Inspections In the context of regulatory compliance for Real-World Evidence (RWE), both audits and inspections play crucial roles, [...]
Real World Evidence (RWE) 101 – A Career of Many Pathways
stuart.mccully2023-08-07T22:28:44+00:00August 7, 2023|2023, RWE 101|
RWE 101 - A Career of Many Pathways Real-world evidence (RWE) refers to the information on health care that is derived from analysis of real-world data (RWD). RWE [...]
Real World Evidence (RWE) 101 – Evolution of Regulatory Affairs
stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Evolution of Regulatory Affairs Real-world evidence (RWE) and real-world data (RWD) are increasingly influencing regulatory affairs in the biopharmaceutical and healthcare industry. This change has been [...]
Real World Evidence (RWE) 101 – Project Managers
stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Project Managers Real-World Evidence (RWE) observational studies and clinical trials are both key elements of medical research, but they involve very different methodologies, aims, and requirements. [...]
Real World Evidence (RWE) 101 – The Tuskegee Syphilis Study – Supplement
The Tuskegee Syphilis Study, conducted between 1932 and 1972 by the United States Public Health Service (USPHS), stands as one of the most infamous and ethically questionable experiments in the history of human research. The study intended to observe the natural history of untreated syphilis. Researchers did not collect informed consent from participants. Researchers did not offer treatment, even after it was widely available. The study was terminated after 40 years following publication of news articles about the study.
“The government induced these men to participate in a study in which the government represented that the participants were being treated for whatever their ailments were…They were never told what their ailment was…They never gave their consent to be involved in a study…Nor did they realise they were part of a study until the story broke in July 1972…Treatment was knowingly withheld for 40 years” – Fred D Gray – Attorney, 8th April 1997
Its repercussions have had far-reaching effects on the regulation of observational studies, medical ethics, and trust in healthcare institutions, especially among minority communities.
- Introduction of Ethical Guidelines: The Tuskegee study helped accelerate the development of ethical standards for observational studies, notably the Belmont Report in 1979. The report outlined three basic principles: respect for persons, beneficence, and justice. It prescribed informed consent, an understanding of potential risks and benefits, and the equitable selection of research subjects. These principles, born out of a response to the unethical practices in Tuskegee and other studies, have become the bedrock of research ethics.
- Introduction of Regulations: In 1974 the National Research Act was signed into law and the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research was formed. In 1991 the Federal Policy for the Protection of Human Subjects (‘Common Rule’) (45 CFR 46) was implemented.
- Informed Consent: One of the main lessons from the Tuskegee study was the importance of informed consent. In the study, participants were not told they had syphilis, nor were they informed about the nature of the experiment. As a result of public outcry, it is now mandatory for researchers to provide potential participants with comprehensive information about the study and its potential risks and benefits.
- Protection for Vulnerable Populations: The Tuskegee study highlighted the need for special protections for vulnerable populations in observational studies. The mostly poor, uneducated African American men involved were exploited due to their socioeconomic status and lack of access to quality healthcare. The fallout from Tuskegee led to additional safeguards for marginalized populations to prevent similar abuses.
- Institutional Review Boards (IRBs): After the Tuskegee study, the requirement for Institutional Review Boards became more widespread. IRBs are responsible for reviewing and monitoring research involving humans to ensure ethical standards are met. Their role is to protect the rights and welfare of the research subjects.
- Transparency and Accountability: The Tuskegee Syphilis Study was marked by a lack of transparency and accountability. The study was conducted without adequate oversight or scrutiny. This led to the development of regulations requiring transparency in the conduct of studies, data sharing, and mechanisms for accountability in the case of ethical breaches.
- Public Trust and Participation: The Tuskegee study severely damaged public trust, particularly among African Americans, in medical research and healthcare institutions. This has implications for the regulation of observational studies, as it underscores the importance of building and maintaining public trust for successful research participation.
- Cultural Competency: The racial implications of the Tuskegee study brought to light the importance of cultural competency in research. Researchers are now required to respect the cultural norms and values of the populations they study, and training in cultural competency has become a norm in many research settings.
- Training in Research Ethics: Following the Tuskegee study, training in research ethics became a requirement for investigators conducting human subject research. This training typically includes a discussion of the Tuskegee study as an example of what not to do.
- International Impact: The Tuskegee study had a global impact on observational study regulation. The Declaration of Helsinki, a set of ethical principles regarding human experimentation, was updated in response to the ethical violations in Tuskegee and similar studies.
“Medical professionals willingly and intentionally let human beings suffer from a treatable, and then later a curable illness. These researchers knew that mercury and arsenic compounds could treat the disease, but the Tuskegee men did not receive the medicine. Later the researchers knew that penicillin could cure the disease, but again, the Tuskegee men did not get the medicine. They didn’t get treated until the 40 year study was discovered and stopped amid public outcry in 1972. It was a disgraceful episode for American Scientists” – Vice President Al Gore, 16th May 1997 [See also…Presidential Apology]
In conclusion, the Tuskegee Syphilis Study has had a profound impact on the regulation of observational studies in the USA.
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
stuart.mccully2023-08-09T15:27:28+00:00August 9, 2023|2023, RWE 101|
RWE 101 - ICH GCP (R3) - Real World Evidence Context Revision 2 of ICH GCP caused confusion to those of us who work with non-interventional studies. The glossary [...]
Real World Evidence (RWE) 101 – Non-Interventional Studies vs Market Health Research
stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Non-Interventional Studies vs Market Health Research Key differences between a non-interventional study (NIS) and market health research include:1. Research Objective: NIS are conducted to examine real-world [...]
Real World Evidence (RWE) 101 – Real World Evidence (RWE) 101 – Audits vs Inspections
stuart.mccully2023-08-09T14:51:12+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Real World Evidence (RWE) 101 - Audits vs Inspections In the context of regulatory compliance for Real-World Evidence (RWE), both audits and inspections play crucial roles, [...]
Real World Evidence (RWE) 101 – A Career of Many Pathways
stuart.mccully2023-08-07T22:28:44+00:00August 7, 2023|2023, RWE 101|
RWE 101 - A Career of Many Pathways Real-world evidence (RWE) refers to the information on health care that is derived from analysis of real-world data (RWD). RWE [...]
Real World Evidence (RWE) 101 – Evolution of Regulatory Affairs
stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Evolution of Regulatory Affairs Real-world evidence (RWE) and real-world data (RWD) are increasingly influencing regulatory affairs in the biopharmaceutical and healthcare industry. This change has been [...]
Real World Evidence (RWE) 101 – Project Managers
stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Project Managers Real-World Evidence (RWE) observational studies and clinical trials are both key elements of medical research, but they involve very different methodologies, aims, and requirements. [...]
Real World Evidence (RWE) 101 – The Tuskegee Syphilis Study (the reason we have the Belmont Report and the Common Rule)
The Tuskegee Syphilis Study, conducted from 1932 to 1972, stands as a notorious example of unethical human research. Its fallout had substantial implications on the regulation of observational studies:
Ethical Guidelines: The Tuskegee study expedited the development of ethical standards, including the Belmont Report (1979). The report emphasized respect for persons, beneficence (acting in a way that brings about positive outcomes and promotes the welfare of others), and justice (the principle of treating people fairly and equitably), all crucial in research ethics.
Informed Consent: The Tuskegee study underscored the importance of informed consent. It is now required for researchers to provide comprehensive information about the study and its potential risks and benefits.
Protection for Vulnerable Populations: The study highlighted the need for protections for vulnerable populations. Additional safeguards have since been implemented to prevent similar abuses.
Institutional Review Boards (IRBs): Post-Tuskegee, the requirement for IRBs became more prevalent. IRBs review and monitor research involving humans to ensure ethical standards.
Transparency and Accountability: The study led to regulations mandating transparency, data sharing, and mechanisms for accountability in the case of ethical breaches.
Public Trust and Participation: The Tuskegee study damaged public trust, particularly among African Americans. This underlines the importance of building and maintaining public trust for research participation.
Cultural Competency: The racial implications of the Tuskegee study highlighted the importance of cultural competency in research. Training in cultural competency has since become a norm.
Training in Research Ethics: The study led to mandatory training in research ethics for investigators conducting human subject research.
International Impact: The study had a global impact on observational study regulation. It influenced updates to the Declaration of Helsinki, an international set of ethical principles regarding human experimentation.
For more details about the Tuskegee Syphilis Study see the RWE 101 Supplement I published today…
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
stuart.mccully2023-08-09T15:27:28+00:00August 9, 2023|2023, RWE 101|
RWE 101 - ICH GCP (R3) - Real World Evidence Context Revision 2 of ICH GCP caused confusion to those of us who work with non-interventional studies. The glossary [...]
Real World Evidence (RWE) 101 – Non-Interventional Studies vs Market Health Research
stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Non-Interventional Studies vs Market Health Research Key differences between a non-interventional study (NIS) and market health research include:1. Research Objective: NIS are conducted to examine real-world [...]
Real World Evidence (RWE) 101 – Real World Evidence (RWE) 101 – Audits vs Inspections
stuart.mccully2023-08-09T14:51:12+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Real World Evidence (RWE) 101 - Audits vs Inspections In the context of regulatory compliance for Real-World Evidence (RWE), both audits and inspections play crucial roles, [...]
Real World Evidence (RWE) 101 – A Career of Many Pathways
stuart.mccully2023-08-07T22:28:44+00:00August 7, 2023|2023, RWE 101|
RWE 101 - A Career of Many Pathways Real-world evidence (RWE) refers to the information on health care that is derived from analysis of real-world data (RWD). RWE [...]
Real World Evidence (RWE) 101 – Evolution of Regulatory Affairs
stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Evolution of Regulatory Affairs Real-world evidence (RWE) and real-world data (RWD) are increasingly influencing regulatory affairs in the biopharmaceutical and healthcare industry. This change has been [...]
Real World Evidence (RWE) 101 – Project Managers
stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Project Managers Real-World Evidence (RWE) observational studies and clinical trials are both key elements of medical research, but they involve very different methodologies, aims, and requirements. [...]
Real World Evidence (RWE) 101 – Ethical Principles and Safeguards for Medical AI in the Context of Real World Evidence
Medical AI applications hold great promise for improving healthcare outcomes, but they also raise ethical concerns related to patient privacy, algorithmic bias, and the reliability of the underlying data. When deploying medical AI in the context of real-world evidence, there are several ethical principles and safeguards that should be considered:
Transparency: Medical AI algorithms should be transparent about how they make decisions, what data they use, and the potential limitations of their predictions. This allows patients and clinicians to better understand the reasoning behind the AI’s recommendations and assess its accuracy.
Data privacy: Medical AI algorithms should comply with data privacy regulations, such as HIPAA in the United States, and should ensure that patient data is protected from unauthorized access, use, or disclosure.
Informed consent: Patients should be informed about how their data will be used by medical AI algorithms and should provide explicit consent for its use. They should also have the right to withdraw their consent at any time.
Fairness and bias: Medical AI algorithms should be designed to minimize bias and ensure that their predictions are fair across different patient populations. This requires careful attention to the selection of training data and the use of appropriate validation methods.
Human oversight: Medical AI algorithms should be designed to augment, not replace, human decision-making. Clinicians should have the ability to review and modify the AI’s recommendations, and patients should have access to human experts to address any concerns or questions they may have.
Accountability: Developers and providers of medical AI applications should be accountable for the accuracy and reliability of their algorithms, and should be transparent about any limitations or uncertainties associated with their predictions.
By following these ethical principles and safeguards, medical AI can be deployed in a responsible and effective manner, enabling healthcare providers to make better-informed decisions and improve patient outcomes.
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
stuart.mccully2023-08-09T15:27:28+00:00August 9, 2023|2023, RWE 101|
RWE 101 - ICH GCP (R3) - Real World Evidence Context Revision 2 of ICH GCP caused confusion to those of us who work with non-interventional studies. The glossary [...]
Real World Evidence (RWE) 101 – Non-Interventional Studies vs Market Health Research
stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Non-Interventional Studies vs Market Health Research Key differences between a non-interventional study (NIS) and market health research include:1. Research Objective: NIS are conducted to examine real-world [...]
Real World Evidence (RWE) 101 – Real World Evidence (RWE) 101 – Audits vs Inspections
stuart.mccully2023-08-09T14:51:12+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Real World Evidence (RWE) 101 - Audits vs Inspections In the context of regulatory compliance for Real-World Evidence (RWE), both audits and inspections play crucial roles, [...]
Real World Evidence (RWE) 101 – A Career of Many Pathways
stuart.mccully2023-08-07T22:28:44+00:00August 7, 2023|2023, RWE 101|
RWE 101 - A Career of Many Pathways Real-world evidence (RWE) refers to the information on health care that is derived from analysis of real-world data (RWD). RWE [...]
Real World Evidence (RWE) 101 – Evolution of Regulatory Affairs
stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Evolution of Regulatory Affairs Real-world evidence (RWE) and real-world data (RWD) are increasingly influencing regulatory affairs in the biopharmaceutical and healthcare industry. This change has been [...]
Real World Evidence (RWE) 101 – Project Managers
stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Project Managers Real-World Evidence (RWE) observational studies and clinical trials are both key elements of medical research, but they involve very different methodologies, aims, and requirements. [...]
Real World Evidence (RWE) 101 – Ethical Foundation of RWE Research
Real-world evidence (RWE) research, which is the study of data from real-world settings, is founded on a number of ethical principles, including:
Respect for autonomy: This principle recognizes the importance of individuals’ ability to make their own decisions regarding their healthcare. In RWE research, this means obtaining informed consent from individuals before using their data.
Beneficence: This principle requires that researchers seek to maximize the benefits of their research while minimizing any potential harm. In RWE research, this means ensuring that the research is designed to answer important questions that will improve health outcomes for individuals.
Non-maleficence: This principle requires that researchers avoid causing harm to study participants. In RWE research, this means minimizing any risks associated with data collection and use, such as breaches of confidentiality.
Justice: This principle requires that researchers treat individuals fairly and equitably, ensuring that the benefits and burdens of the research are distributed fairly. In RWE research, this means ensuring that the use of data is transparent and that individuals are not unfairly excluded from research opportunities.
In addition to these principles, RWE research is also guided by ethical standards established by international bodies, such as the World Medical Association’s Declaration of Helsinki. These standards emphasize the importance of obtaining informed consent, protecting privacy and confidentiality, and ensuring that research is conducted in a manner that respects the dignity and rights of study participants.
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
stuart.mccully2023-08-09T15:27:28+00:00August 9, 2023|2023, RWE 101|
RWE 101 - ICH GCP (R3) - Real World Evidence Context Revision 2 of ICH GCP caused confusion to those of us who work with non-interventional studies. The glossary [...]
Real World Evidence (RWE) 101 – Non-Interventional Studies vs Market Health Research
stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Non-Interventional Studies vs Market Health Research Key differences between a non-interventional study (NIS) and market health research include:1. Research Objective: NIS are conducted to examine real-world [...]
Real World Evidence (RWE) 101 – Real World Evidence (RWE) 101 – Audits vs Inspections
stuart.mccully2023-08-09T14:51:12+00:00August 9, 2023|2023, RWE 101|
RWE 101 - Real World Evidence (RWE) 101 - Audits vs Inspections In the context of regulatory compliance for Real-World Evidence (RWE), both audits and inspections play crucial roles, [...]
Real World Evidence (RWE) 101 – A Career of Many Pathways
stuart.mccully2023-08-07T22:28:44+00:00August 7, 2023|2023, RWE 101|
RWE 101 - A Career of Many Pathways Real-world evidence (RWE) refers to the information on health care that is derived from analysis of real-world data (RWD). RWE [...]
Real World Evidence (RWE) 101 – Evolution of Regulatory Affairs
stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Evolution of Regulatory Affairs Real-world evidence (RWE) and real-world data (RWD) are increasingly influencing regulatory affairs in the biopharmaceutical and healthcare industry. This change has been [...]
Real World Evidence (RWE) 101 – Project Managers
stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
RWE 101 - Project Managers Real-World Evidence (RWE) observational studies and clinical trials are both key elements of medical research, but they involve very different methodologies, aims, and requirements. [...]
Brazil – Government Publishes Resolution that Strengthens the Role of Research Participants
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ARGENTINA | Guide to Writing Ethical Considerations
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