Great Potential, Limited Practice: RWE Use in FDA MAAs Limited to Orphan Drugs
Despite growing interest in using real-world evidence (RWE) in regulatory approvals, limited information is available about how these guidelines have been applied in practice. Our targeted literature review and case series of drug applications containing RWE (2021-2023) suggests RWE use is still often limited to first-in-class treatments for orphan indications. It seems that regulators are be receptive to RWE in principle, but successful drug applications appear to rely on the entire body of evidence, including indication, methodological rigor, and the use of effective, transparent, and fit-for-purpose RWE. While the FDA has long used RWE for post-approval monitoring and evaluation, use of RWE for BLAs/NDAs has typically been limited to rare disease indications. The FDA, along with global regulatory bodies, have issued guidelines about RWE incorporation into a wider range of regulatory submissions. However, our findings suggest ongoing uncertainty about how to leverage RWD effectively