Lessons learned on the design and the conduct of Post-Authorization Safety Studies: review of 3 years of PRAC oversight

Pierre Engel*, Mariana Ferreira Almas, Marieke Louise De Bruin, Kathryn Starzyk, Stella Blackburn, Nancy Ann Dreyer

*Corresponding author for this work
    23 Citations (Scopus)

    Abstract

    Aims: To describe and characterize the first cohort of Post-Authorization Safety Study (PASS) protocols reviewed under the recent European pharmacovigilance legislation. Methods: A systematic approach was used to compile all publicly available information on PASS protocols and assessments submitted from July 2012 to July 2015 from Pharmacovigilance Risk Assessment Committee (PRAC) minutes, European Medicines Agency (EMA) and European Network of Pharmacovigilance and Pharmacoepidemiology (ENCePP) webpages. Results: During the study period, 189 different PASS protocols were submitted to the PRAC, half of which were entered in the ENCePP electronic register of post-authorization studies (EU-PAS) by July 2015. Those protocols were assessed during 353 PRAC reviews. The EMA published only 31% of the PRAC feedback, of which the main concerns were study design (37%) and feasibility (30%). Among the 189 PASS, slightly more involved primary data capture (58%). PASS assessing drug utilization mainly leveraged secondary data sources (58%). The majority of the PASS did not include a comparator (65%) and 35% of PASS also evaluated clinical effectiveness endpoints. Conclusions: To the best of our knowledge this is the first comprehensive review of three years of PASS protocols submitted under the new pharmacovigilance legislation. Our results show that both EMA and PASS sponsors could respectively increase the availability of protocol assessments and documents in the EU-PAS. Protocol content review and the high number of PRAC comments related to methodological issues and feasibility concerns should raise awareness among PASS stakeholders to design more thoughtful studies according to pharmacoepidemiological principles and existing guidelines.

    Original languageEnglish
    JournalBritish Journal of Clinical Pharmacology
    Volume83
    Issue number4
    Pages (from-to)884-893
    Number of pages10
    ISSN0306-5251
    DOIs
    Publication statusPublished - 2017

    Keywords

    • ENCePP
    • new pharmacovigilance legislation
    • PASS
    • PRAC
    • transparency

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