Emanuel Krebs, Tania Bubela, Melanie McPhail, Christopher McCabe, Dean A Regier
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引用次数: 0
摘要
对新药或新适应症而言,上市许可要求有充分的临床有效性证据。在大多数司法管辖区,实质性证据没有明确定义。卫生监管机构行使自由裁量权,对早期或不太成熟的证据越来越宽容。为了与灵活的证据标准保持一致,我们主张对证据阈值采用基于原则和背景的方法。我们的方法以信息价值(VoI)框架为基础,旨在平衡加速授权、低治疗价值和安全性之间的潜在利弊。在我们的 VoI 框架中,当进一步研究的预期净健康价值小于或等于零时,就存在实质性证据。我们通过两个案例将这一方法具体化,这两个案例反映了不确定性、风险偏好和时间投入等实时决策因素。随着证据评估格局向灵活性转变,有必要对风险评估方法进行迭代和明确界定。清晰的定义将提高透明度,增强利益相关者和监管者的责任感。
Putting the substance in substantial evidence: an evidence-based approach to flexible drug regulation.
For new drugs or indications, substantial evidence of clinical effectiveness is required for market authorization. In most jurisdictions, substantial evidence is not explicitly defined. Health regulators exercise discretion and are increasingly tolerant of earlier or less mature evidence. To align with flexible evidentiary standards, we argue for the adoption of a principle and, context-based approach to the evidence threshold. Our approach aims to balance the potential benefits and harms of accelerated authorization, low therapeutic value, and safety, based on a value of information (VoI) framework. In our VoI framework, substantial evidence exists when the expected net health value of further research is less than or equal to zero. We operationalize this approach through two case examples that mirror real-time decision factors such as uncertainty, risk preferences and time inputs. As the evidentiary assessment landscape shifts towards flexibility, iterative and clearly defined approaches to risk assessment are warranted. Clarity will stimulate transparency and accountability for both stakeholders and regulators.
期刊介绍:
Frontiers in Medicine publishes rigorously peer-reviewed research linking basic research to clinical practice and patient care, as well as translating scientific advances into new therapies and diagnostic tools. Led by an outstanding Editorial Board of international experts, this multidisciplinary open-access journal is at the forefront of disseminating and communicating scientific knowledge and impactful discoveries to researchers, academics, clinicians and the public worldwide.
In addition to papers that provide a link between basic research and clinical practice, a particular emphasis is given to studies that are directly relevant to patient care. In this spirit, the journal publishes the latest research results and medical knowledge that facilitate the translation of scientific advances into new therapies or diagnostic tools. The full listing of the Specialty Sections represented by Frontiers in Medicine is as listed below. As well as the established medical disciplines, Frontiers in Medicine is launching new sections that together will facilitate
- the use of patient-reported outcomes under real world conditions
- the exploitation of big data and the use of novel information and communication tools in the assessment of new medicines
- the scientific bases for guidelines and decisions from regulatory authorities
- access to medicinal products and medical devices worldwide
- addressing the grand health challenges around the world