How should the PFDD guidance for medicines development inform the conduct of RW research?

What PFDD guidance can teach us about better real-world research

My career has been spent spanning the medicines development lifecycle, from first-in-human dosing to commercialization. The view from those different vantage points has left me convinced of one thing: if we want to understand how a treatment affects people, patient-focused research cannot be confined to a single phase of development. We need a continuous thread of evidence, running from early research through clinical trials and into routine care. Indeed, I believe in it so much that I curated 2 books on this topic, generously sponsored by my previous employer [1,2]!

It sounds obvious. Yet it remains surprisingly rare.

We are in 2026 and development, medical affairs, commercial, and real-world evidence teams still too often work alongside one another rather than together. Patient-centricity, patient-focused medicines development, and patient experience data can fall into the gaps between them, valued by everyone but fully owned by no one.

In my experience this challenge persists despite the multiple reorganizations redrawing the structure seen across the industry in recent years, many of them intended to support a more joined-up, patient-focused and commercially-savvy approach to medicines development.

A false divide between development and the real world

Later-stage development: Phase 3b-4
Early-stage development: Phase 1b-3a
Vitaccess works across the product lifecycle, helping to shape patient experience data (PED) strategy and generate evidence from Phase 1b through to Phase 4.
The breadth of settings, stages and methods is one of the things that drew me to Vitaccess. Yet I have noticed a familiar divide: our customers for Phases 1b to 3a tend to sit in development, HEOR and clinical operations functions, and our customers for Phases 3b to 4 are generally living in medical affairs and real-world evidence (RWE) teams.

These latter teams recognize the value of patient-centricity, but they are not usually familiar with best scientific practices that have evolved within medicines development.

This is why I refer to the US FDA’s PFDD guidance, the EMA’s PED framework and tools from PFMD into conversations about real-world research with medical affairs and RWE teams. The response is often a reasonable one: why use “medicines development” guidance when alternatives (such as the ISPOR-ISPE Patient-Centered RWE recommendations [3] and the recent ISPOR Real-World PRO Good Practices Report [4]) already exists?

I think there are three good reasons.

1. RWE guidance focuses on PROs, while PFMD guidance embraces the wider PED landscape

FDA, EMA and PFMD guidance, recommendation and summary documents discuss various types of PED, including qualitative elicitation of patient experiences, COA (including patient-reported outcome; PRO) research, patient preference initiatives, and the use of digital health technologies (DHTs) to collect PED. The ISPOR/ISPE guidance focuses primarily on one specific type of PED: data captured through PROs. PROs are a very important way of capturing individual patient data in a standardized way and they are increasingly credible and easy to collect as part of real-world research and healthcare practice. However, PROs represent only one part of the patient experience story.

2. PFDD guidance represents scientific best practice for generating generalizable, interpretable and un-biased PED which extends beyond clinical trials

The principles for real-world PRO selection and administration in RWE studies (such as prospective observational studies or registries) as outlined in the ISPOR good practices report [4] are consistent with the FDA and EMA principles of clear, feasible objectives developed in collaboration with patients, use of “fit for purpose” (well-defined, reliable, valid, sensitive and interpretable) PRO instruments, an adherence to quality standard for implementation, and a pre-specified approach to statistical analysis.

However, the ISPOR guidance focuses on what should be considered when collecting PRO data, rather than providing a comprehensive framework for generating high-quality PED. The FDA’s PFDD guidance fills that gap. Most of the principles proposed by FDA holds in an RWE context; it just needs to be considered in a pragmatic way, understanding the differences between the settings.

3. Patient-focused medicines development and RWE/ commercial activities are part of the same evidence journey

Patients’ experiences of treatment can only be fully understood through a continuous golden thread of research conducted all the way through medicines development and healthcare delivery. Figure 1 shows how real-world patient-centered research informs medicines development and how medicines development informs healthcare. It is certainly not a linear pattern though, with RWE and research in medicines development inherently intertwined. The true golden thread is scientific rigor.

High quality, scientifically robust, interpretable research that answers strategic questions across this lifecycle is needed to support a forward-thinking value proposition for a novel intervention.

There are some important differences to consider when conducting patient-focused research in medicines development and the real-world. For example, the rigorous standardization and strict timing of PRO administration is not always possible (or necessary) in RWE contexts, and clinical care infrastructures cannot always cope with the collection of PED [4]. Further, data privacy and security need to be considered in quite a different way [5]. But there are more similarities than differences; patient burden and compliance should be considered across both; patient and clinical team education on the purpose and importance of PRO data collection is vital for high quality data; approaches to missing-data handling must be carefully considered to ensure data interpretability; and robust information technology (IT) infrastructures are a pre-requisite to support data capture [3,4].

Figure

Medicine Development And Post Approval
In summary, it is appropriate – if not important – to consider FDA, EMA and PFMD guidance, recommendations and summary documents to inform the conduct of real-world PED research. Doing so helps to ensure quality, robust and interpretable data which can be used to inform an understanding of value, concern and opportunity from the patient perspective. After all, patients are the ultimate beneficiaries of the medicines we develop and the healthcare systems that deliver them. And I am sure that that a deeper understanding of patients’ experiences, needs and priorities is ultimately what we all want at all phases of medicines development, commercialization and healthcare delivery.

References

[1] Reaney, M. (ed) (2023). Using Patient Experience Data to Evaluate Medical Interventions. New York: IQVIA. Available at: https://www.iqvia.com/library/publications/using-patient-experience-data-to-evaluate-medical-interventions-full-book. Accessed 10 July 2026.

[2] Reaney, M. (ed) (2025). Patient-centricity in the Biopharmaceutical Industry: Are We Nearly There Yet? New York: IQVIA. Available at: https://www.iqvia.com/-/media/iqvia/pdfs/library/publications/2025/iqvia-patient-centricity-perspectives-book.pdf. Accessed 10 July 2026.

[3] Oehrlein, E. M., Schoch, S., Burcu, M., Fairchild, A. O., Perfetto, E. M., Mattingly, T. J., II, & the Patient-Centered Real-World Evidence Working Group. (2023). Developing patient-centered real-world evidence: Emerging methods recommendations from a consensus process. Value in Health, 26(1), 28–38.

[4] Rylands, A. J., Maruszczyk, K., Aiyegbusi, O. L., Snyder, C., Yelland, E., Calvert, M. J., & ISPOR Real-World Patient-Reported Outcomes Task Force. (2026). Designing and implementing real-world patient-reported outcomes—Emerging recommendations: A good practices report of an ISPOR Task Force. Value in Health, 29(6), 921–931. 

[5] Oehrlein, E. M., Graff, J. S., Harris, J., & Perfetto, E. M. (2019). Patient-community perspectives on real-world evidence: enhancing engagement, understanding, and trust. Patient,12(4), 375–381.
Sam Llewellyn

Chief Scientific Officer

Supporting evidence-generation with expertise

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