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Term of the Day

Natural history study

A natural history study is a preplanned observational study intended to track the course of a disease over time, identifying demographic, genetic, environmental and other variables that correlate with its development and outcomes in the absence of intervention, or under standard of care. Designs may be retrospective (chart review of existing records) or prospective (longitudinal follow-up of a cohort or registry).

Natural history data is particularly important in rare and paediatric diseases, where randomised placebo-controlled trials may be infeasible or unethical. The FDA (guidance on rare disease natural history studies, 2019) and the EMA accept well-designed natural history studies to define endpoints and biomarkers, identify patient subgroups, estimate sample sizes and, in some cases, serve as external or historical control arms for single-arm trials supporting orphan products.

Because they are non-interventional, natural history studies fall outside the CTR and are governed by national law (for example France's MR-003 or MR-004 reference methodologies) and by the GDPR. They typically involve secondary use of medical records, long-term follow-up, genetic data and small populations in which anonymisation is rarely achievable, so pseudonymisation, a DPIA and a robust research legal basis under Art. 9(2)(j) are essential. Registries maintained by patient organisations or academic consortia raise additional questions of joint controllership and data access governance.

C

Clinical outcome assessment (COA)

A clinical outcome assessment (COA) is a measure that describes or reflects how a patient feels, functions or survives. It is distinct from a biomarker, which is a measured physiological or molecular indicator. COAs are used to define endpoints in clinical trials and to support labelling claims.

The FDA and EMA recognise four types of COA, defined by who reports the outcome: the patient-reported outcome (PRO), the clinician-reported outcome (ClinRO), the observer-reported outcome (ObsRO) reported by a parent or caregiver, and the performance outcome (PerfO) based on a standardised task. Each instrument must be validated for the target population, and translations must be linguistically validated.

COAs are increasingly captured electronically as eCOA on tablets, smartphones or wearables. Because they record symptoms, mood, cognition and function, COA data is data concerning health and often reveals sensitive information about daily life. Bring-your-own-device eCOA also raises questions about device identifiers, app permissions and vendor access that must be addressed in the DPIA and the informed consent form.

Does every clinical outcome assessment need formal FDA qualification?

No. FDA states that formal COA qualification is not required for successful use in clinical trials and drug development. Suitability still depends on the intended concept and context of use. Sponsors can seek advice within a particular development programme or use the qualification pathway where broader reuse is the objective.