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Comment on Real-World Data: Assessing Electronic Health Records and Medical Claims Data to Support Regulatory Decision-Making for Drug and Biological Products

Published

December 2021

Comment on Real-World Data: Assessing Electronic Health Records and Medical Claims Data to Support Regulatory Decision-Making for Drug and Biological Products

ΩBrad Jordan, Senior Director, Regulatory Policy, submitted comments on behalf of Flatiron Health to the U.S. Food and Drug Administration on the recent Draft Guidance: Real-World Data: Assessing Electronic Health Records and Medical Claims Data to Support Regulatory Decision-Making for Drug and Biological Products.

Flatiron welcomed the release of this foundational draft guidance and applauded the FDA for its efforts to advance the use of RWD/E in regulatory-decision making. The key points are highlighted below. The full letter is available for download at this link.

    • Health technology organizations should be included in FDA's Advancing RWE Program.

    • The FDA should adopt a risk-based approach to study-specific verification and validation.

    • We encourage the FDA to exercise the appropriate regulatory flexibility needed to support the use of RWE in regulatory decision-making.

    • Health technology organizations, sponsors and the FDA should work together to align on appropriate data-quality guidelines applicable to sources of RWD.

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