April 2009
Update June 2011
PATIENT REGISTRIES IN THE
FIELD OF RARE DISEASES
Overview of the issues
surrounding the establishment,
management, governance and
financing of academic registries
RDTF Report on patient registries in the field of rare diseases (June 2011)
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Table of contents
Introduction
3
Part I
5
Definition of a patient registry (PR)
5
Purposes of patient registries in the field of rare disease
5
Typology of data collections, other than registries
8
Status of data collections
9
Points to consider when planning a patient registry
in the field of rare diseases
10
Steps to consider when developing a PR in the field of RD
12
Part II
15
Ethical and legal issues
15
Consent requirement
15
Protection of patient privacy
17
Transparency, oversight and ownership
17
Bibliography
19
Annex 1: List of workshop participants and contributions
19
Annex 2: List of rare disease registries in Europe
21
RDTF Report on patient registries in the field of rare diseases (June 2011)
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Introduction
Patient registries and databases constitute key instruments for the development of clinical
research in the field of rare diseases (RD), and the improvement of patient care and
healthcare planning as well as social, economical and quality of life outcomes. They are the
appropriate way to pool scarce data without bias for epidemiological and/or clinical research.
They are vital to assess the feasibility of clinical trials, to facilitate the planning of appropriate
clinical trials and to support the enrolment of patients and to assess the impact of new
interventions.
Registries of patients treated with orphan drugs are particularly relevant as they allow the
gathering of evidence on the effectiveness of the treatment and on its possible side effects,
keeping in mind that marketing authorisation is usually granted at a time when evidence is
still limited although already somewhat convincing.
When established, databases should be maintained and their use optimised through
exchange of data between interested parties. However, the status of such databases is not
well defined and most institutions have no written policies or agreements regarding this
activity.
Regulations concerning registries are in early stages in most European countries and, with
the multiplicity of actors and of rules at MS level, the situation is difficult to comprehend. No
guidelines are available yet on best practices for exchanging and sharing data. The notion of
return of benefits to research subjects/communities is fairly recent.
Databases are expensive to establish and maintain. They require the cooperation of many
healthcare providers and require careful management. PR should only be established when
financial resources and expertise are present to support them. Furthermore, PR systems tend
to have added value if the disease in question has a good prospect for intervention, control,
prevention and for research that can lead to these ends.
They are of high interest to researchers, industrial partners, healthcare professionals,
patients and patient organisations, and, ultimately, for the community. It is difficult to
separate research conducted by the non-profit and for-profit sectors, as researchers from
both sectors are often involved in the same projects. Whilst this enables effective technology
transfer, it also gives rise to concerns about conflicts of interest. There is a need to promote
confidence in research based on data collections.
Patient registries have been in place for several decades in sectors such as cancer, birth
defects and cardiovascular diseases. This long and broad history of data collection is the basis
on which to build guidelines for registration of patients with a RD although RD patient
registries have some additional features which make them specific:
the scarcity of cases and the complexity of these diseases imposes a large
geographical coverage of the data collection which implies multiple collaborations
and exchanges of data, usually trans-national;
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most RD are genetic in origin and a large proportion of them may have one family
member affected, which implies that it is desirable that family related cases be
traceable;
the cost of establishing and maintaining a PR is nearly equal for a common disease
as it is for a RD, although budgets are more difficult to obtain for the latter.
The European Commission, in its Communication: “Rare diseases: Europe’s challenge”
emphasizes the strategic importance of PR in the field RD.
“Collaborative efforts to establish and maintain data collection should be supported,
providing that these resources are accessible through agreed upon rules. Many research and
public health networks financially supported by DG RTD and by DG SANCO have put in place
such shared infrastructures, which have been proven to be very efficient tools in improving
knowledge and organising clinical trials.”
“Areas to be supported by the MS and the European Commission include: quality standards,
including development of strategies and tools for periodical monitoring of the quality of
databases and for database upkeep; a minimum common set of data to be collected for
epidemiological and public health purposes; attention to user-friendliness, transparency and
connectivity of databases; intellectual property, communication between databases/registries
(genetic, more generically diagnostic, clinical, surveillance-driven, etc). Importance should be
given to linking international (European) databases to national and/or regional databases,
when existing.”
To discuss these issues and produce recommendations from a health professional’s
perspective, the Rare Diseases Task Force organised a workshop on 13 March 2008 in Paris,
France, to which 23 experts (see Annex 1) from 10 European countries were invited. This
document was finalised as an output of this workshop where a preliminary version was
presented and discussed.
The present document is based on a compilation of several previously published documents
which are listed at the end of the report. An updated
1
list of patient registries in Europe in
the Orphanet Report Series is also provided in Annex 2. The report and annex has been
updated in June 2011 by the Scientific Secretariat of the European Union Committee of
Experts on Rare Diseases (EUCERD).
This document forms part of a project financed by the European Commission, DG Sanco
(Scientific Secretariat of the Rare Disease Task Force Contract n° 2004105).
1
Updated in January 2011.
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Part I
Definition of Patient Registry (PR)
The WHO definition of “patient registry” is “a file of documents containing uniform
information about individual persons, collected in a systematic and comprehensive way, in
order to serve a pre-determined scientific, clinical or policy purpose
2
”. It does not pre-judge
the amount of collected data which can be minimal or extensive, but implies continuity, as
distinct from a cross-sectional survey.
The US National Committee on Vital and Health Statistics
3
defines registries as “an organized
system for the collection, storage, retrieval, analysis, and dissemination of information on
individual persons who have either a particular disease, a condition (e.g., a risk factor) that
predisposes (them) to the occurrence of a health-related event, or prior exposure to
substances (or circumstances) known or suspected to cause adverse health effects”.
In its most simple form, a PR consists of a collection of paper cards kept inside a “shoe box”
by physicians. Nowadays PR are collections of computerised data.
It is usual to distinguish between population-based registers, which refer to a geographically
defined population and aim to register all cases in that population, and registers based on
clinical centres or other criteria where the population coverage may not be clear. These two
types of register have different uses. It may also be useful to distinguish exhaustive and non-
exhaustive registers (the latter are possibly not registers by some definitions) - an exhaustive
register seeks to include ALL cases which fulfil the inclusion criteria. Non-exhaustive registers
(or databases) can however be very useful for finding patients for clinical research for
example.
Purposes of PR in the field of RD
Monitoring prevalence and incidence
PR can be established to monitor incidence or prevalence, especially in relation to early
warning of increases. Where incidence/prevalence is expected to be stable over long
periods, an ad hoc study may be more cost-effective. However, for rare diseases a register
and ad hoc study are often effectively the same, as a relatively long period of time is needed
2
Brooke EM. The current and future use of registers in health information systems. Geneva: World
Health Organization; 1974. Publication No. 8.
3
Available at: Frequently Asked Questions about Medical and Public Health Registries. The National
Committee on Vital and Health Statistics http://ncvhs.hhs.gov/9701138b.htm. Accessed April 2009.
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to establish a precise incidence/prevalence, and to look for differences between populations
if relevant.
Establishing natural history
The straightforward purpose of patient registries is to document the natural history of the
disease, meaning its characteristics, management and outcomes with or without treatment.
For rare diseases of genetic origin, the purpose may also be to establish a genotype-
phenotype correlation. The natural history may be variable from one population group to
another and usually changes over time, especially if a new therapy becomes available. The
best example is the change in survival of patients with lysosomal storage diseases since the
introduction of enzyme replacement therapies. Registries need to keep pace with the ever
changing complexity of clinical factors in rare diseases especially in the context of increased
life expectancy and ageing.
Monitoring safety: outcome surveys/post-marketing surveys
Registries have been often created in the past to monitor safety. In that context registries
serve as an active surveillance system for the occurrence of unexpected or harmful events for
products or interventions in general and in particular for drugs used off-label, which is the
case for most drugs used by patients living with a rare disease. In the context of orphan drugs
or new medical or surgical intervention, it is likely to be a necessary step as usually little is
known at the time the intervention is implemented, and certainly not enough to be sure that
any adverse effects have been properly assessed.
However registries to monitor safety are of limited interest for uses other than safety
monitoring as they only monitor treated cases which may be a minority of cases or a skewed
sample of cases. Usually they are product registries rather than disease registries. If there is
more than one product from two different manufacturers for a given disease, this will lead to
the establishment of two separate product registries with limited value, which will not allow
the comparison of outcomes with each of the products.
Assessing clinical effectiveness
Registries can also be established to provide data for assessing the clinical effectiveness or
the cost-effectiveness of new interventions in a real-world setting. This is required because
the clinical studies performed to assess the clinical efficacy of new treatments are based on
studies of selected patients following an “ideal protocol”, which differ from the clinical
practice afterwards when the treatment is implemented in the healthcare setting. This is why
more and more regulatory authorities and healthcare insurers request that a registry be
implemented when an orphan drug receives a marketing authorisation. This type of registry
is much more interesting than the previous type as it includes all patients, not only the
treated patients. However, registries have to be designed specifically to assess cost-
effectiveness in order to accomplish this purpose even if cost-effectiveness may be difficult
to assess in rare diseases.
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Measuring quality of care / plan services
Registries may also be established to measure the quality of care. It is usually compared to
standards which have been established and which are considered as “gold standards”. The
IOM definition for quality of care is “the degree to which health services for individuals and
populations increase the likelihood of desired health outcomes and are consistent with
current professional knowledge”. This type of registry is useful to identify disparities between
health care outcomes and provide evidence for improving them. It is very interesting in a
European context as health care systems, as well as attention given to patients with rare
diseases, are very diverse. It is also useful for healthcare planning and gold standards exist
only for a very limited number of rare diseases. With regard to quality of care self-reporting
PR can complement reports from physicians and cover issues such as quality of life and social
issues.
Performing research into aetiology
PR are also the basis for research into causes when not firmly established, providing that the
potential causal factors are registered as well.
Providing an inventory of patients to re-contact for clinical research
In the field of rare diseases, a reason for establishing a patient registry is also to collect
enough data on a given disease to make it visible and to motivate researchers and Industry to
work on it. It seems to be an effective approach, providing that the registry is designed
properly to generate useful information.
Another reason is to have an inventory of patients to re-contact for participation in
epidemiological studies, clinical trials or for Health Technology Assessment to monitor real
access to treatments. In that case the data needed on each patient is limited to the diagnosis
and the contact details. It should be better named a “contact list” rather than a PR.
Yet another reason to make key data, such as genetic status, diagnostic criteria etc, available
to research groups, is to reduce the repetitive collection of the same data thereby reducing
demands on participants and their carers.
Of course most registries have the ambition to serve more than one purpose, although it is
not always possible. Sticking to selected purposes requires a lot of attention in the design
phase. It is common to mix up goals such as management of patients and management of
data for research purpose. It is desirable for the format of data to be compatible between
these two types of data registration systems to allow extraction, but the other aspects are
too different to be accommodated by one system. Another common mistake is for registries
to accept to collect data which they cannot successfully access, which can potentially
paralyse the project.
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Typology of data collections, other than registries
Registries are only one specific type of data collection. Several other types of data collection
exist with their own merit and limit. They are reviewed below with reference to their
particular type of use.
Health system data
These are computerised hospital files where the patient diagnosis is coded using a defined
nomenclature, usually the International Classification of Diseases (ICD) developed by WHO.
They are clinical tools, adapted to counting patients using specific types of healthcare
services. They are used by healthcare managers. They are not designed for research purposes
although they may sometimes be used for research purposes. Other sources can also be used
such as death certificates or health insurance data. In the field of rare diseases their use is
limited as the ICD does not yet provide specific codes for more than 240 RD. This should
change with the release of ICD 11, and if these systems were perfect and if ICD coding for RD
were perfect, much of the data we need would be available from health system data.
Healthcare provider databases
These are defined as permanent registrations of patient information in a systematic way,
carried out by healthcare providers on the basis of their referrals. It is a passive ongoing
registration activity. The advantage of such a system is its low cost, as there is no cost
attached to the identification of cases, as they are referred through the healthcare system.
The limits of this approach include the fact that registered cases are not a true
representation of the general population but rather a biased sample, usually biased towards
more severe cases or cases from higher socio-economic classes. If the data collection is done
properly, the data set may be of interest for some research purposes, but not suitable for
epidemiologic studies, unless it can be established that all the cases are referred to the
collecting centre. Observatories of cases are also called hospital registries.
Ad hoc studies
This type of data collection is targeted at offering the possibility to answer one or more
specific research questions. This is one shot data gathering, which may be repeated in at
another time. The data collected is in the exact format required for the anticipated analysis.
The protocol of the study is designed to ensure a clear answer to the research question(s).
This implies an adequate definition of the sampled population, an adequate size of the
sampled population, and an adequate management of the study to minimise the number of
non-responders.
The ad hoc study is the most efficient instrument for research purposes as their protocol
is well adapted to the research needs (the sample is fully representative and thus the results
are conclusive) and the cost of the study is much lower that any type of permanent data
collection, as the study takes place during a limited period of time. Ad hoc studies are flexible
instruments with protocols adapted to the most recent discoveries about a disease.
There are several types of ad hoc studies, namely clinical trials, prospective cohorts,
retrospective cohorts, case-control studies, cross-sectional (prevalence) studies, etc.
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Ad hoc studies can be used in combination with longer term registries to answer specific
research questions
Cohorts
In the context of a registry, the data collection can be transversal (all defined patients are
registered once) or longitudinal (data is collected at different points in time for the same
patient). If there is a systematic follow-up protocol, the dataset is defined as a cohort. For
rare disease clinical research, cohorts are highly desirable as they are usually the only way to
collect enough data to allow a proper analysis, due to the very small number of cases.
Status of data collections
There are several types of data collections:
In “anonymous” data collections the data is originally collected without identifiers and is
impossible to link to their sources. This type of data collection is adequate for incidence and
prevalence studies for instance, but is less appropriate for clinical research. The advantage of
this technique is to maximise data protection and to ease the collaboration between
researchers.
In “anonymised” data collections, data is originally identified, but is then irreversibly
stripped of all identifiers and are impossible to link to their sources.
In “indirectly identifiable” data collections, data is unidentified for research purposes, but
can be linked to their sources through the use of a code. This is the most common type of
data collected for clinical research.
In “directly identifiable” data collections, identifiers, such as a name, patient number, or
clear pedigree location, are attached to the data. This is, for example, the case for hospital
files. The use of this type of data is regulated by strict rules in most, if not all, countries. Rules
concerning this type of data collection differ from one country to another.
It is important that the degree of anonymity of the data is made clear to patients at the time
of consent as uncertainty in this area is becoming more and more of a barrier to
participation.
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Points to consider when planning a patient registry in
the field of rare diseases
The initial steps in planning a registry should consider the following points:
“Articulating the purpose and the objectives of the registry”
A clearly defined purpose helps clarify the need for certain data, including their scope
and level of details. It prevents collecting large amount of data of limited value for the
targeted objectives.
“Determining if the data being sought has already been collected elsewhere, totally or
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