A HYBRID, MULTI-SOURCE REAL-WORLD EVIDENCE FRAMEWORK FOR POST-AUTHORIZATION STUDIES: DESIGN CONSIDERATIONS FOR EU JOINT CLINICAL ASSESSMENT READINESS
Author(s)
Ombretta Palucci, MS1, Ashish Deshpande, MD2, Michelle Leavy, MPH2.
1OM1 B.V., Amsterdam, Netherlands, 2OM1, Inc., Boston, MA, USA.
1OM1 B.V., Amsterdam, Netherlands, 2OM1, Inc., Boston, MA, USA.
OBJECTIVES: The EU Health Technology Assessment Regulation (2021/2282) mandates binding evidentiary standards for Joint Clinical Assessments (JCAs), requiring real-world evidence (RWE) that is comparative, patient-centered, and generated through methodologically rigorous post-authorization studies. Conventional single-source observational designs are poorly suited to meet these requirements across diverse patient populations and health system contexts. There is need for flexible, multi-source study architectures integrating primary and secondary data collection while maintaining analytical coherence and regulatory defensibility. This paper describes a hybrid framework combining site-based primary data collection with registry-based secondary data linkage, assessing its applicability to JCA requirements in a multi-country post-authorization setting.
METHODS: The framework draws on three complementary data sources, each serving a distinct evidentiary role. First, prospective data capture via electronic data capture (EDC) systems provides structured, query-controlled collection aligned to pre-specified protocol endpoints. Second, automated EHR extraction reduces transcription burden, improves data completeness, and enables near real-time access to longitudinal clinical information without additional site workload. Third, secondary use of established national registries extends geographic reach and sample size, leveraging population-level data for subgroup and comparative effectiveness analyses. Patient-reported outcomes are collected digitally at pre-specified intervals to meet patient-relevance standards required in HTA submissions. All sources are harmonized into a single analytical dataset. Study design elements are prospectively mapped to JCA PICO requirements, with data quality controls aligned to Good Pharmacoepidemiology Practice (GPP) and ICH E6(R3) standards.
RESULTS: Application of this framework yields a harmonized, JCA-ready dataset from three complementary sources. The modular architecture accommodates variable national digital infrastructure, enabling consistent cross-country implementation regardless of site-level health system maturity.
CONCLUSIONS: This hybrid framework demonstrates that post-authorization studies can be designed prospectively to meet evolving EU JCA evidentiary standards without sacrificing real-world representativeness. The approach is therapeutic-area-agnostic and adaptable across sponsor contexts, offering a replicable model for generating fit-for-purpose RWE within the European regulatory landscape.
METHODS: The framework draws on three complementary data sources, each serving a distinct evidentiary role. First, prospective data capture via electronic data capture (EDC) systems provides structured, query-controlled collection aligned to pre-specified protocol endpoints. Second, automated EHR extraction reduces transcription burden, improves data completeness, and enables near real-time access to longitudinal clinical information without additional site workload. Third, secondary use of established national registries extends geographic reach and sample size, leveraging population-level data for subgroup and comparative effectiveness analyses. Patient-reported outcomes are collected digitally at pre-specified intervals to meet patient-relevance standards required in HTA submissions. All sources are harmonized into a single analytical dataset. Study design elements are prospectively mapped to JCA PICO requirements, with data quality controls aligned to Good Pharmacoepidemiology Practice (GPP) and ICH E6(R3) standards.
RESULTS: Application of this framework yields a harmonized, JCA-ready dataset from three complementary sources. The modular architecture accommodates variable national digital infrastructure, enabling consistent cross-country implementation regardless of site-level health system maturity.
CONCLUSIONS: This hybrid framework demonstrates that post-authorization studies can be designed prospectively to meet evolving EU JCA evidentiary standards without sacrificing real-world representativeness. The approach is therapeutic-area-agnostic and adaptable across sponsor contexts, offering a replicable model for generating fit-for-purpose RWE within the European regulatory landscape.
Conference/Value in Health Info
2026-11, ISPOR Europe 2026, Vienna, Austria
Value in Health, Volume 29, Issue 12S
Code
RWD190
Topic
Health Technology Assessment, Real World Data & Information Systems, Study Approaches
Topic Subcategory
Data Protection, Integrity, & Quality Assurance
Disease
No Additional Disease & Conditions/Specialized Treatment Areas