ABSTRACT
Person-generated health data (PGHD) are valuable to study outcomes relevant to everyday living, to obtain information not otherwise available, for long-term follow-up and in situations where decisions cannot wait for traditional clinical research to be completed. While there is no dispute that these data are subject to bias, insights gained may be better than an information void, provided the biases are understood and acknowledged. People will share information known uniquely to them about exposures that may affect drug tolerance, safety and effectiveness, e.g., using non-prescription and complementary medications, alcohol, tobacco, illicit drugs, exercise, etc. Patients may be the best source of safety information when long-term follow-up is needed, e.g., the 5-15-year follow-up required for some gene therapies. Validation studies must be performed to evaluate what people can accurately report and when supplementary confirmation information is needed. But PGHD has already proven valuable in quantifying and contrasting COVID-19 vaccine benefits and risks, and for evaluating disease transmission and the accuracy of COVID-19 testing. Going forward, PGHD will be used for patient-measured and patient-relevant outcomes, including regulatory purposes, and will be linked to broader health data networks using tokenization, becoming a mainstay for signals about risks and benefits for diverse populations.
ABSTRACT
BACKGROUND: : Since the new legislation on risk management, which came into force in November 2005, an EU Risk Management Plan (EU-RMP) is a required part of the authorization dossier of innovative drugs licensed in the EU. The EU-RMP can include additional risk minimization activities (RMAs) to strengthen the benefit-risk balance of a drug. This study describes the additional RMAs of centrally authorized medicinal products authorized between 1 January 1995 and 1 January 2010. METHODS: : The European Public Assessment Reports of all centrally authorized products were analysed to identify characteristics of the product (active substance, authorization date, Anatomical Therapeutic Chemical classification), the additional RMAs and the corresponding safety concerns (classified at Medical Dictionary for Regulatory Activities (MedDRA) System Organ Class level). RESULTS: : Additional RMAs were identified for 58 of the 391 active substances that were authorized as of 1 January 2010. The proportion of active substances with additional RMAs was 5% among those authorized before, and 29% among those approved after the new risk management legislation. Since the new legislation, blood products and antineoplastic and immunomodulating agents most often had additional RMAs. All active substances with additional RMAs required the provision of educational material, most frequently involving healthcare professionals (n = 57) and the patient (n = 31). Thirty-three active substances required additional RMAs on top of the provision of educational material, most frequently including patient monitoring and screening (n = 19). CONCLUSIONS: : The proactive pharmacovigilance approach is evolving and the number of products with additional RMAs is growing since the introduction of the EU-RMP. The provision of educational material is the primary additional risk minimization strategy in the EU. The effect of additional RMA implementation has to be explored.
