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Good practice standards and inspection for real-world data sources

Trials are inspected to check the data are real and traceable. Do the same for the hospital databases used to make regulatory decisions.

Clinical trial data are governed by Good Clinical Practice and inspected; real-world data sources used in regulatory submissions are not. The proposal is a 'GCP for real-world data': standards for provenance, traceability to source records, curation documentation, fitness-for-purpose assessment and inspection rights, with accreditation of data sources. The FDA's RWE framework and EMA's DARWIN EU data quality framework are starting points.

Hypothesis
Accredited data sources will produce RWE that regulators accept as supportive evidence in a substantially higher share of submissions, and audit will reveal material provenance errors in a minority of current sources.
Rationale
Regulators discount RWE partly because they cannot verify it; accreditation with inspection is how the same problem was solved for trials and for laboratories (CLIA, ISO 15189).
What would test it
Pilot accreditation with five data sources (two commercial, two academic, one registry); publish audit findings and regulator uptake of RWE from accredited versus non-accredited sources over two years.
Maturity
early clinical
Who has to act
regulator
Cost to try
Medium ($1M to $50M)
Years to first evidence
3
Bottlenecks it attacks

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