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<p>Bayesian methods are increasingly used in clinical development and pharmacovigilance, especially when evidence is sparse, accrues sequentially, or must incorporate external information. Translation of high-level regulatory principles into an auditable, submission-ready Bayesian package remains inconsistent. Publicly available FDA, EMA, and ICH documents relevant to Bayesian implementation were reviewed, including Bayesian-specific guidance and recommendations that materially shape Bayesian analyses (for example, adaptive designs, externally controlled trials, estimands/sensitivity analyses, and pharmacovigilance signal management). Findings are synthesized into a practical framework organized around four deliverables that repeatedly emerge as regulatory decision drivers: (1) governed external information and prior specification, including quantification of prior influence and safeguards for prior–data conflict; (2) decision criteria paired with simulation-based characterization of operating characteristics under realistic scenarios; (3) structured sensitivity analyses that probe priors, borrowing, model forms, estimand-related assumptions, and key pharmacovigilance definitions; and (4) transparency and reproducibility, including pre-specification, traceability of data sources and transformations, and clear interpretation of Bayesian outputs for the intended decision (triage vs. confirmation). These deliverables are mapped to post-authorization pharmacovigilance workflows, where Bayesian shrinkage and hierarchical modeling are frequently used despite method-neutral guidance. The resulting framework provides a concise “regulatory-ready” evidence blueprint applicable across development programs and pharmacovigilance systems. This synthesis incorporates FDA’s January 2026 draft guidance on Bayesian methodology in clinical trials of drug and biological products [<CitationRef CitationID="CR9">9</CitationRef>], which increases cross-agency expectations for prior justification, prospective evaluation of operating characteristics, and computational transparency.</p>

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A Regulatory-Ready Bayesian Evidence Framework across Clinical Development and Pharmacovigilance: Practical Expectations from FDA, EMA, and ICH Guidance

  • 期刊论文

  • 发表日期：

    2026年7月14日

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  • Carlos G. Bernaus,
  • Maria Lilia Bournissen

摘要

Bayesian methods are increasingly used in clinical development and pharmacovigilance, especially when evidence is sparse, accrues sequentially, or must incorporate external information. Translation of high-level regulatory principles into an auditable, submission-ready Bayesian package remains inconsistent. Publicly available FDA, EMA, and ICH documents relevant to Bayesian implementation were reviewed, including Bayesian-specific guidance and recommendations that materially shape Bayesian analyses (for example, adaptive designs, externally controlled trials, estimands/sensitivity analyses, and pharmacovigilance signal management). Findings are synthesized into a practical framework organized around four deliverables that repeatedly emerge as regulatory decision drivers: (1) governed external information and prior specification, including quantification of prior influence and safeguards for prior–data conflict; (2) decision criteria paired with simulation-based characterization of operating characteristics under realistic scenarios; (3) structured sensitivity analyses that probe priors, borrowing, model forms, estimand-related assumptions, and key pharmacovigilance definitions; and (4) transparency and reproducibility, including pre-specification, traceability of data sources and transformations, and clear interpretation of Bayesian outputs for the intended decision (triage vs. confirmation). These deliverables are mapped to post-authorization pharmacovigilance workflows, where Bayesian shrinkage and hierarchical modeling are frequently used despite method-neutral guidance. The resulting framework provides a concise “regulatory-ready” evidence blueprint applicable across development programs and pharmacovigilance systems. This synthesis incorporates FDA’s January 2026 draft guidance on Bayesian methodology in clinical trials of drug and biological products [9], which increases cross-agency expectations for prior justification, prospective evaluation of operating characteristics, and computational transparency.