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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.

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Study Data Tabulation Model (SDTM)

The Study Data Tabulation Model (SDTM) is a CDISC standard that defines how clinical trial data collected on subjects should be organised and formatted for submission to regulatory authorities. Data is arranged in standard domains, each a dataset with predefined variables: Demographics (DM), Adverse Events (AE), Concomitant Medications (CM), Exposure (EX), Laboratory Results (LB), Vital Signs (VS), Medical History (MH), Disposition (DS) and many others, grouped into interventions, events, findings and special-purpose classes. The SDTM Implementation Guide specifies variable names, controlled terminology and rules for each domain.

SDTM datasets are created by mapping the data collected in the eCRF (ideally already structured according to CDISC's CDASH collection standard) and external data from laboratories, imaging and eCOA vendors into the standard domains. They form the basis for the ADaM analysis datasets. Submission in SDTM format has been mandatory for NDA and BLA submissions to the FDA since 2016 and to Japan's PMDA since 2020, and is accepted by the EMA; conformance is checked with validation tools such as Pinnacle 21.

SDTM datasets contain subject-level health data, including dates, demographics and detailed medical history, which makes them pseudonymised personal data rather than anonymous, particularly for rare diseases or small trials. Their submission to non-EU regulators is an international data transfer that must be disclosed in the informed consent form, and their sharing with data-sharing platforms or partners requires a compatibility assessment and appropriate contractual and technical safeguards. Programmers and statisticians at CROs handling SDTM data act as processors.

Does SDTM replace the analysis datasets used for statistical reporting?

No. SDTM organises study data into standard tabulation structures, while ADaM supports analysis-ready datasets and traceability of statistical results. The standards serve connected but different purposes. Plan the mapping and derivation process so that reviewers can follow the path from collected observations to tabulations and then to analyses.