FDA Sets a High Bar for Externally Controlled Trials: Does Your Data Measure Up?
By
Evelyn Pyper
Apr 17, 2023 • 5 min read
BACKGROUND
Earlier this year, the Food and Drug Administration (FDA) released a draft guidance for industry titled “Considerations for the Design and Conduct of Externally Controlled Trials for Drug and Biological Products”. It is the latest in a series of guidance documents on the use of real-world evidence (RWE) in regulatory decision-making under the FDA’s RWE Program. This recent draft guidance provides recommendations to sponsors and investigators who are considering the use of externally controlled trials to provide evidence of a drug product’s safety and effectiveness.
As the FDA describes, an externally controlled trial involves comparing the outcomes in participants receiving the test treatment according to a protocol to outcomes in a group of people external to the trial who had not received the same treatment. The external control arm can be a group of people, treated or untreated, from (i) an earlier time (historical control) OR (ii) during the same time period (concurrent control) but in another setting. There are a number of sources of patient-level data that have the potential to serve as a control arm, including data from other clinical trials, electronic health records (EHR), medical claims, and registries.
THE GUIDANCE DOES:
Provide helpful information and direction for the design and analysis of externally controlled trials to study the effectiveness and safety of drugs, including discussion of threats to the validity of trial results from potential bias.
Share considerations for communicating and consulting with the FDA early on plans for an externally controlled trial.
Advise sponsors to ensure access to patient-level data (in both treatment and external control arms) when submitting to the FDA.
THE GUIDANCE DOES NOT:
Address other types of external controls (e.g. using summary-level estimates instead of patient-level data).
Delve into details of the design and analysis of a natural history study (although it does call out its importance).
Discuss the reliability and relevance of various sources of RWD that could be used in an externally controlled trial.
Describe considerations for using external control data to supplement a control arm in a traditional randomized controlled clinical trial.
While the document does not directly compare different data sources in terms of appropriateness for use in an externally controlled trial, it does shed light on important, cross-cutting considerations for patient-level, real-world data to serve as a control arm. Here we highlight some key challenges and PicnicHealth-driven solutions:
As guided by the FDA, the suitability of an externally controlled trial design requires evaluation on a case-by-case basis. So what informs this decision-making for an individual case? Clinical presentation, disease severity, prognosis, trial aims, and any preliminary evidence on the drug product are all important factors to consider when assessing appropriateness of using an external control. It is especially critical to have a strong understanding of the natural history of disease. When natural history is well-established and it’s known that a disease does not improve without intervention or with currently available therapies, then historical information can potentially serve as the control group.
The need for comprehensive natural history data comes front-and-center in our work with life sciences partners, who often face challenges of incomplete or unavailable data—especially for rare diseases. PicnicHealth’s direct-to-patient approach enables complete capture of a patient’s journey across all sites and providers, unstructured and structured data, and both retrospectively and prospectively from medical records and patient-reported outcomes. This depth and breadth of data supports a variety of pharma use cases, including natural history of disease studies and external control arms for trials. To learn more about our curated RWD cohorts or our customized cohorts and patient registry offerings, contact us today.
PicnicHealth’s providers can schedule virtual visits with study participants to conduct assessments required by the study protocol. Using clinical expertise, these assessments help evaluate participants' symptoms, overall health, and functional ability.
2. Diagnostics
The PicnicHealth care team can order specific diagnostic tests, such as labs or imaging, if they weren't part of the patient's routine care. This ensures that sponsors have all the necessary data to address their unique research questions.
3. Safety and adverse event reporting
PicnicHealth’s clinical team can provide support to ensure appropriate safety reporting. This includes monitoring for safety events to support safety adjudication.
4. Primary Investigator (PI) oversight
The PI of the PicnicHealth Virtual Site provides clinical oversight to ensure appropriate study conduct, including assessing whether the study is following study protocol, meeting compliance with regulatory standards and good clinical practice guidelines, collecting data accurately, and maintaining documentation and producing progress reports as required.
25,966
patients onboarded to platform
1,427,368
medical visits processed
56,861
facilities provided medical records
255,101
healthcare providers
95+
research programs
12
published posters and manuscripts
10
partnerships with top 30 pharma
New Research
Discover how PicnicHealth data powered medical research in 2021
This year, experts from PicnicHealth joined podcasts, webisodes, virtual summits and much more to speak to the importance of patient-centric approaches when building complete, deep real-world datasets.
Sickle cell (SC) is the most common inherited blood disorder in the United States. Red blood cells become rigid and shaped like crescent moons, preventing oxygen from getting to parts of the body. This can cause fatigue, severe pain, organ damage or stroke.
List the names of all the doctors, hospitals, and other facilities your loved one visits regularly, along with those they have visited in the past. Try to go back as far as you can, striving for at least the last 5-10 years, but do your best. Even if you can’t remember them all, having a strong baseline can help you quickly identify gaps in records.
Ensure You Have the Appropriate Legal Status
It is important to make sure that you are fully empowered to make decisions on behalf of your loved one with Alzheimer’s. Your relationship status with the patient may not be enough to legally give you access to your loved one's medical information. It is a good idea to talk to an expert about securing special legal status, such as Power of Attorney (POA), a legal document that allows an individual to name someone as their decision maker should they no longer be able to make decisions on their own.
Gather and Organize the Medical Records in One Place
It’s important to have all of your loved one’s medical records together in one spot. This makes it much easier for you and your loved one’s physicians to accurately map the patient’s medical journey and more easily share information between doctors. Fortunately, tools exist to make record management and access simple. A free resource like PicnicHealth helps you collect and organize all of this information. PicnicHealth’s intuitive timeline allows you to pinpoint data across the medical history, eliminating your need for keeping heavy binders filled with paper records or keeping track of multiple software portal logins.
Review the Medical Records to be an Informed Advocate
The better you understand your loved one's medical history, the better you can advocate on their behalf. Access and understanding of this information will help you to ask informed questions with physicians. Through regular communication backed by the data in the medical records, you can help your loved one’s care team develop a more successful care plan.
Learn more about PicnicHealth’s commitment to the Alzheimer’s community and the Alzheimer’s Association
When you’re juggling appointment times and insurance claims, putting a robust support system together might not strike you as the most urgent task. Investing the time to cultivate relationships with people can turn to in times of need will pay dividends. The next time you need a last-minute ride or just someone to listen, you won’t be on your own. There are many condition-specific support groups and support groups for caregivers generally in person or online. In addition to the encouragement and empathy they provide, support groups can be a helpful source of tips, resources, and recommendations for navigating caregiving.
2
Stay organized.
The backbone of effective caregiving is organization. Keep medical information, appointment schedules, and medication lists in order. Use a planner or a digital service like PicnicHealth to stay on top of your responsibilities. This attention to detail can prevent future complications and reduce day-to-day stress.
3
Explore treatments and clinical trials.
We’ve seen incredible breakthroughs in treatment over the past couple of years, powered by patients and their caregivers participating in research. Stay in the loop about the latest in medical advancements and available resources that could benefit your loved one. Whether it’s a new therapy option or a community service that aids independence, being informed can make a world of difference in the quality of care you provide.
4
Make time for self-care.
It may seem self-centered to focus on self-care—but when you feel good, you can be a better caregiver. Whether it’s exercise, a mindfulness practice, a soak in the bath, or just time to rest when you need it, carve out those moments in the day when you can unwind, reset, and stay healthy mentally and physically. Think of it as building up your reserves of kindness, patience, and understanding—which can only benefit your loved one. No one can pour from an empty cup.
Having trouble managing your loved one's medical records?
Easily manage all of your loved one's medical records and contribute to ongoing Alzheimer's research with PicnicHealth.
Tip: Download or print the poster at the end of this article to review before your next appointment!
However, it's important to consult with a healthcare provider or registered dietitian to determine the appropriate amount of protein for your individual needs. In general, a diet with moderate protein intake (about 0.8 grams per kilogram of body weight per day) is recommended for people with kidney diseases.
Learn more about contributing to IgAN research with PicnicHealth.
A tablet, phone, or laptop with a working camera, microphone, and stable internet connection.
A quiet, distraction-free area with enough space to walk a few steps if applicable.
A chair that you can use during any movements or tasks you’ll be asked to perform.
The tripod mailed to you via Amazon.
What to Expect
Before your video call:
Book Your Assessment
Visit your to-do list on your PicnicHealth Research Dashboard or click the scheduling link sent to your email. Note: Search for “New task for the ORBIT-CIDP Study" to find the video call scheduling link.
Receive Confirmation
Check your email for a confirmation with your scheduled video call time and instructions.
On the day of your video call:
Click on Video Link
Join your personal video call using the link we sent by email, or text message, or find it on your research dashboard.
Meet your nurse
A Registered Nurse (RN) will guide your virtual assessment, which will last about 30 minutes.
Complete the Physical Activity Assessment (INCAT)
The nurse will guide you through questions and, if needed, physical tasks to help researchers gain a deeper understanding of CIDP.
Complete the Movement Assessment (Optional)
If you participate, a nurse will guide you through three short recorded movement activities to complete as best you can:
Chair Task
While seated with your arms crossed over your chest and hands on oppositeshoulders, you’ll be asked to stand up, remain standing for 20 seconds, and then sit back down.
Arm Movement Task
While seated with your arms resting at your sides, you’ll be asked to raise both arms out to the sides until they meet above your head, then lower them back to your lap.
Finger Dexterity Task
While seated, raise your right hand with fingers extended. Touch your thumb to each fingertip in order, then reverse. Repeat with your left hand. This will then be repeated with your left hand.
Earn Compensation
Receive up to $55 for your participation:
$25 for completing the Physical Activity Assessment (INCAT).
$30 for the Optional Movement Assessment.
Recording: Your research assessment may be recorded to ensure accurate data collection. If you participate in the optional Movement Assessment, it will also be recorded. These recordings may capture your voice and responses, but identifiable information like your face, name, or background will be removed to protect your privacy.
Opt Into the Smart Insole Study Activity
Complete the opt-in survey to confirm your participation.
Receive Your Smart Insoles
Your smart insoles will be shipped to your home via FedEx and should arrive within 1 week.
Create Your Account
You’ll receive an email from Celestra Health with your account details. Follow those steps to set up your account.
If you don’t see an email from Celestra Health in your inbox, please check your spam or junk folder.
Download the App
After creating your account, you’ll be directed to a landing page with links to the App Store or Google Play. Use the link to download the correct version of the app for your device.
For illustrative purposes only, your insoles may look different
Log In
Open the app and log in using the email address and password you used when creating your account.
Enable Permissions
For iOS users: Enable Motion & Fitness and allow access to Apple Health.
For Android users: Enable Activity Recognition permissions.
Connect Your Insoles
Turn on Bluetooth, and follow the app's instructions to connect your smart insoles.
Enable Notifications
Enable push notifications to stay updated on reminders and activity progress.
For illustrative purposes only, your insoles may look different
Start Walking Sessions
When you’re ready to perform a walking session, tap ‘Start’ on the Ad Hoc Walking task card in the app.
Smart insoles are designed to fit comfortably into any pair of closed shoes
Need Help?
Should you need to contact Celestra Health support for any reason, you can submit a ticket through the Help section of the app by tapping the Submit A Ticket card and filling out the form. A Celestra Health representative will typically respond within one business day.
A fully charged device (smartphone, tablet, or laptop) with a working camera, microphone, and stable internet connection.
A quiet, well-lit space that is free from distractions.
Good lighting so your face is clearly visible; having a small flashlight or your phone’s flashlight nearby can help with skin, scalp, or joint checks.
Flexible device positioning so you can easily adjust or prop up your device hands-free if the research staff asks to view specific areas (such as your face, hands, or scalp).
Space to move in case you are briefly asked to stand or walk a few steps.
Your medication information, including your current steroid(s) and BENLYSTA® (belimumab) — either the medication bottles or a list with doses and schedule.
Time to focus without interruptions so the visit can be completed comfortably.
Before Your Video Call:
Schedule your visit
Use the scheduling link on your PicnicHealth Research Dashboard or the link sent to your email. Tip: Search your inbox for “New task for the BEACON-SLE Study - schedule your remote visit” to find the scheduling email.
Check your confirmation
You’ll receive an email with your appointment time and instructions for joining the video call.
On the Day of Your Video Call:
Join the call
Click the Zoom link sent to you by email or text message, or use the link available on your research dashboard.
Meet with the research staff member
They will ask you structured questions about your health and any lupus symptoms you’ve experienced over the past 30 days.
If needed, they may guide you through a few simple visual checks (such as looking at your skin, hair, joints, or mouth). You can always tell them if you’re not comfortable with anything.
Receive Compensation
You’ll receive up to $60 for completing your visit.
The FDA's one-trial default shifts burden to the real world. See what it means for sponsors and how patient-mediated RWE supports the full development lifecycle
Learn how Amgen used PicnicHealth to rapidly enroll their study and generate real-world evidence for a rare disease therapy — with patient-mediated data collection that reduces burden.
Discover how AI and patient-mediated data are transforming clinical trials — from synthetic control arms to real-world evidence that puts patients first