Real World Evidence (RWE) 101 – Ethical Imperatives (CIOMS 2023)
Informed decision making with patients typically relies on evidence from clinical trials that describe the likely benefits and toxicities. However, patients treated in everyday practice tend to be older and more frail, to have poorer function and performance status, and to have more comorbidities and less social support than those selected to participate in clinical trials. Thus, generalisability to typical patient populations treated in daily practice is often limited. Kennedy-Martin et al explored the generalisability of RCTs in cardiology, mental health, and oncology by assessing studies comparing participants in such trials with those in everyday clinical practice. Patients treated in everyday clinical practice tended to be older, were more often women, and had more comorbidities; 71% of studies concluded explicitly that RCTs were not broadly representative of real-world patients, in particular, pregnant and lactating women are a very large population that is often entirely unrepresented in clinical trials. Furthermore, patients enrolled in trials were treated according to guidelines more often and received more in-hospital procedures. Strict selection criteria for RCTs meant that participants were at a much lower risk of adverse events compared with patients treated in clinical practice.
If the efficacy-effectiveness gap means that patients are being given inaccurate information about the potential benefits and risks of treatments, then decisions made using that information may be being made without valid informed consent, disrespecting patient’s autonomy and putting them at risk of avoidable harm. The efficacy-effectiveness gap also raises important issues regarding justice; if resource allocation decisions, including which treatments are funded, are made using evidence that is biased by the efficacy-effectiveness gap, then those decisions will also be flawed, with potentially wide implications for patients. Ultimately, the efficacy-effectiveness gap undermines the gold standard status of RCTs, and actually suggests that it would be unethical to continue with such a flawed representation of real-world effects on patients. Increasing use of RWE is one important way to fill the efficacy-effectiveness gap and augment the evidence from RCTs. This should not be seen as dropping the gold standard, or diminishing the standard of evidence required; rather, enhancing and supplanting RCT evidence with RWD can instead be viewed as reinforcing the gold standard with platinum plating.
Source: Section 4.2 (Ethical arguments for incorporating more RWE) of the CIOMS Draft Guidance – Real-World Data and Real-World Evidence in Regulatory Decision Making (6 June 2023)
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
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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 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 [...]
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stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
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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|
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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 [...]
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stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
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Real World Evidence (RWE) 101 – Publications
The term RWE stands for Real-World Evidence, which is evidence derived from real-world data (RWD). RWD are data relating to patient health status and/or the delivery of health care routinely collected from a variety of sources.
Ethical approval is needed for the publication of RWE studies in international peer-reviewed journals for several key reasons:
[1] Participant Protection: Ethical approval ensures that the rights, safety, and well-being of the study participants are protected. It guarantees that the study has been designed to minimize harm and discomfort to the participants.
[2] Informed Consent: Ethical review boards (RECs/IRBs) ensure that participants have given informed consent. This means participants are made aware of the nature of the study, its purpose, the procedures involved, the potential risks and benefits, and their rights, including the right to withdraw from the study at any time without penalty.
[3] Privacy and Confidentiality: Ethical approval also ensures that the researchers have a plan in place to protect participant’s privacy and confidentiality. This is particularly important in RWE studies, where the data may come from various sensitive sources such as electronic health records, insurance claims databases, patient registries, and more.
[4] Avoidance of Bias: Ethics committees help ensure that the study is designed in a way that will minimize bias, increasing the validity of the results.
[5] Trustworthiness of the Research: By requiring ethical approval, journals are able to guarantee a certain level of quality control. Ethical approval can indicate that the research has been conducted appropriately and that the results are trustworthy.
[6] Compliance with International Standards: Ethical approval ensures that research is conducted in line with the globally recognized ethical guidelines and principles such as the Declaration of Helsinki e.g., the International Committee of Medical Journal Editors “Recommendations” (Link: https://lnkd.in/er-Sj5py). Also, according to the National Health Commission of China, when academic journals publish the results of human life science and medical research, they shall confirm that the research has been approved by the ethics review committee. Researchers should provide relevant proof (Article 29 of the 2023 Ethical Review Measures).
By requiring ethical approval, peer-reviewed journals ensure that the research they publish is ethical, credible, and respectful of participant rights. This is crucial in maintaining trust in the research community and the broader public who may ultimately benefit from the research findings.
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|
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stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
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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|
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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 [...]
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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 [...]
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stuart.mccully2023-08-07T21:50:20+00:00August 7, 2023|2023, RWE 101|
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Real World Evidence (RWE) 101 – Consent to Participate in Research vs Consent to Access and Process Sensitive Healthcare Data (GDPR)
Consent to participate in research and consent to access and process sensitive healthcare data are two different but overlapping types of consent, each governed by distinct legal and ethical principles. In the context of Real-World Evidence (RWE) studies:
[1] Consent to Participate in Research: This is the informed consent given by individuals to participate in a research study. Informed consent is a process by which researchers provide potential and enrolled participants with information about the study (purpose, procedures, risks, benefits, alternatives), and the participants voluntarily agree to participate. This consent can be withdrawn at any time, at which point the individual’s participation in the study would end.
[2] Consent to Access and Process Sensitive Healthcare Data: This relates to the consent given by individuals to have their personal and sensitive health data accessed and used for specific purposes, such as research. This type of consent is governed in Europe by the General Data Protection Regulation (GDPR). Under the GDPR, the use of health data is considered a processing of special category data and requires explicit consent, which must be freely given, specific, informed, and unambiguous.
In a RWE study, both types of consent may be (are) needed. The first ensures that participants agree to be part of the study and understand what will happen during the study. The second ensures that participants agree to their data being used in the manner specified, and it provides protections around how their data can be stored, transferred, and otherwise processed.
One key difference between these two types of consent is that withdrawal of consent to participate in the research study generally means the individual will not be part of the study going forward, but it does not necessarily mean that the data collected up to that point cannot be used. In contrast, under the GDPR, if an individual withdraws their consent to data processing, not only does the data processing have to stop, but in many cases, the data collected up to that point cannot be used further and may need to be deleted.
Another difference is that, while there are legal and ethical requirements to obtain informed consent for research participation in most cases, there are certain circumstances under which health data can be processed for research purposes under the GDPR without obtaining explicit consent, such as if the processing is necessary for reasons of public interest in the area of public health, or if the data has been anonymized.
In both cases, the principles of transparency, respect for persons, and their autonomy are paramount. Proper management of both types of consent is crucial for ethical research and for maintaining trust with study participants.
Real World Evidence (RWE) 101 – ICH GCP (R3) – Real World Evidence Context
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stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
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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|
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stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
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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|
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stuart.mccully2023-08-09T15:02:58+00:00August 9, 2023|2023, RWE 101|
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stuart.mccully2023-08-07T22:02:40+00:00August 7, 2023|2023, RWE 101|
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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|
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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
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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
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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. [...]
NORWAY | Norwait Study – Deterioration for Several Participants in a Controversial Observational Cancer Study
RWR CONTEXT
Observational studies, by definition, are low or no risk studies for patients. Ordinarily, there is no impact on the healthcare or treatment of patients. The purpose of the research is to ‘observe’ patients during the routine treatment as decided by their treating physician. However, if an observational study results in the witholding of treatment (as per the Tuskegee Syphilis Study) this can result in significant and fatal results for patients.
The Norwait study is an example of an observational study where procedural failings have resulted in patients with active cancers being included in an observational study, which was contrary to the inclusion criteria, resulting in treatment being withheld.
6 FEBRUARY 2023 – The ‘Research Ethics’ magazine (Magasinet Forskningetikk), an independent magazine on research ethics by the National Research Ethics Committees (FEK), has published an update on the Norwait study [Link] [1].
Contrary to our own impact criteria for regulatory updates, this will not (immediately) impact the regulatory requirements for conducting real world research in Norway. However, given the significance of the scientific, regulatory, and ethical breaches we have included this as a significant update. Researchers conducting observational studies in Norway should be aware of the Norwait study.
“We must not forget that the Norwait case is about people”
The Norwait Study – Overview and Background
According to the National Research Ethics Committees (FEK), the aim of the Norwait research project was to examine a wait-and-see scheme for patients who had become completely free of rectal cancer after radiotherapy, a so-called complete response [1].
Surgeons at the Haukeland University Hospital (HUS) included patients even if their cancer was not completely gone. These patients should have had surgery immediately instead of being included in a wait-and-see scheme. Decisive treatment was thus delayed, according to Norwegian Patient Injury Compensation (NPE) [1].
In 2021, Norwait’s steering group itself carried out an investigation (monitoring) of the inclusion at the various hospitals. This was done by surgeons associated with the project.
The monitoring revealed that at least 16 out of 31 patients had residual cancer when they were included in the study. They should therefore not have been included. Only two HUS patients were documented and included [1].
The monitors went through the inclusion at all seven hospitals that participated in Norwait, and concluded that all the hospitals except HUS had “complied with the protocol to a large extent” [1].
The Norwegian Health Authority’s Conclusion
The Norwegian Health Authority concluded in November 2022 that a number of offences had occurred in Norwait, and has also reported to the police [1]:
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- Helse Bergen HF and Helse Stavanger HF have breached the requirements for soundness and internal control.
- The project manager has breached requirements for professional integrity.
- The project manager has breached the reporting obligation.
- Many of the offences and deviations are serious.
- Data about the patients included at Haukeland must come out of the scientific study.
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The Sør-West police district is now investigating the case in collaboration with the West police district. This is the first time the police are investigating whether there have been criminal breaches of the Health Research Act [1].
Norwegian Patient Compensation (NPE) Conclusions
“We must not forget that the Norwait case is about people”…emphasizes Anne-Mette Gulaker, director of Norwegian Patient Injury Compensation (NPE)
Norwegian Patient Compensation (NPE) has concluded in several cases that HUS patients had a worse prognosis and were harmed by being part of Norwait [1].
“Several had the cancer spread, and the prognosis worsened due to delayed treatment”, says NPE director Anne-Mette Gulaker, to Magasinet Forskningetikk [1].
Nine individual cases have so far been received, and only from patients who were included via the Haukeland University Hospital (HUS). NPE has so far provided compensation to seven patients who suffered injuries as a result of the study. Five of these received a worse prognosis for their cancer. Two cases are still being processed [1].
“Our case management shows that the consequences for some have been catastrophic”, according to NPE director Anne-Mette Gulaker, to Magasinet Forskningetikk [1].
In one patient, during the wait-and-see period, the cancer spread from the rectum to the lungs and lymph, and the cancer became incurable. In another case, the patient died, from the same cause [1].
Common to those who have been approved by the NPE is insufficient examination and documentation before they were included in the study. In some cases, the patients were included in the wait-and-see scheme even though physical examination showed residual wounds and tumor tissue [1].
Research Transparency is Important
In the wake of the conclusions from the Norwegian Health Authority and Norwegian Patient Compensation (NPE), several actors in the professional community have become involved in the debate about Norwait. None of them provide information on how the affected patient group is faring [1].
From NPE’s point of view, however, it is important to say whether the failure in Norwait has had consequences for the patients [1].
“Transparency is always important, especially when something goes wrong. In NPE, we have detailed knowledge of how things have gone wrong for certain patients. We want to ensure that the knowledge from the specific cases does not disappear in the debate. We must not forget that this case is about people. People who have been hit hard by the failure of the project” says NPE director Anne-Mette Gulaker [1].
NPE director Anne-Mette Gulaker describes the case as unique [1]…
”There is no doubt that this is a research scandal”
What Next?
The police investigation is ongoing and the state administrator is in the process of investigating whether the Norwait patients at HUS received proper health care. We’ll provide updates when they become available.
References
1. National Research Ethics Committees (FEK) – Research Ethics Magazine – Deterioration for Several Participants in a Controversial Observational Cancer Study (February 2023)