PV Modules

MODULE 6: CAUSALITY ASSESSMENT

Causality assessment is the clinical step in pharmacovigilance where a medically-qualified reviewer (or a multidisciplinary team for complex cases) evaluates whether the suspected medicine is likely to have caused the adverse event (AE). The outcome influences regulatory reporting, labeling, signal detection, and clinical follow-up. Below I cover purpose, principles, common methods, a step-by-step approach, examples, documentation, pitfalls, and best practices.

1) Purpose — why we do causality assessment

  • Decide whether an event is possibly, probably, or unlikely related to a drug.
  • Determine whether the case needs expedited regulatory reporting (e.g., SUSAR: serious, unexpected, and suspected causal relationship).
  • Inform medical management (stop drug, supportive care, rechallenge decisions).
  • Support signal detection and safety surveillance.
  • Provide a transparent clinical rationale that can be audited.

2) Key principles and inputs used

Causality is not purely algorithmic — it’s a clinical judgement supported by evidence. Typical inputs:

  • Temporal relationship: time from drug start (or dose change) to AE onset.
  • Dechallenge: improvement when drug withdrawn.
  • Rechallenge: recurrence on re-exposure (strong evidence if ethical/available).
  • Plausibility: pharmacology, known ADR profile, class effects.
  • Alternative explanations: underlying disease, other medications, infections, lab abnormalities.
  • Dose–response: AE related to dose or accumulation.
  • Objective data: labs, biopsy, ECG, imaging.
  • Previous reports: literature, company safety database, spontaneous reporting systems.
  • Quality of information: completeness and reliability of the case.

3) Common structured methods / scales

These are tools to make the process consistent. They differ in design and use case.

A. WHO-UMC System (widely used in regulatory context)

Categories: Certain, Probable/Likely, Possible, Unlikely, Conditional/Unclassified, Unassessable/Unclassifiable.
Relies on temporal relationship, dechallenge/rechallenge, alternative causes, and prior knowledge.

B. Naranjo Algorithm (questionnaire with score)

A scored checklist (e.g., +2 for previous conclusive reports, +1 for temporal relationship, etc.). Common in clinical research but less used for regulatory spontaneous reports because it can over-simplify.

C. Specialized algorithms

  • RUCAM for drug-induced liver injury (DILI).
  • Liverpool ADR Causality Assessment Tool for certain complex ADRs.

D. Company/Regulatory Algorithms

Many sponsors create SOP-aligned causality templates combining clinical narrative plus a chosen method (often WHO-UMC) for consistency.

4) Step-by-step practical approach (how a medical reviewer should proceed)

Step A — Review the case source documents

  • Read all source documents (HCP notes, discharge summary, lab reports, autopsy, ECG, concomitant meds).
  • Confirm completeness of key data: onset date/time, drug start/stop dates, dose, dechallenge/rechallenge details.

Step B — Establish temporality

  • Can the timing support causation?
    • Example windows: minutes–hours for anaphylaxis, days–weeks for rash, weeks–months for some organ toxicities.
  • If timing is implausible → probably unlikely.

Step C — Exclude alternative causes

  • Look for infections, new diagnoses, disease progression, interactions, overdose, contaminants.
  • Consider co-medications that are known causes.

Step D — Examine dechallenge / rechallenge

  • Positive dechallenge (improvement after stopping) supports causality.
  • Rechallenge with recurrence is strong evidence — but rarely done intentionally.

Step E — Assess biological plausibility and prior knowledge

  • Is the AE listed in the product label or prior literature? Is there a known mechanism?
  • If unexpected but biologically plausible, it may be “possible” or “probable” depending on other evidence.

Step F — Consider objective data & lab tests

  • Abnormal LFTs, eosinophilia, autoantibodies, ECG changes, biopsy results all add weight.

Step G — Decide on category & document rationale

  • Use your chosen method (e.g., WHO-UMC) and write a concise justification: facts and reasoning. Avoid vague statements.

5) WHO-UMC categories — how to interpret them (practical cues)

  • Certain
    • Time relationship plausible.
    • Cannot be explained by disease/other drugs.
    • Response to withdrawal plausible.
    • Definitive pharmacology or objective evidence (lab) or positive rechallenge.
  • Probable / Likely
    • Reasonable time relationship.
    • Unlikely to be explained by other causes.
    • Reasonable response to dechallenge.
    • Rechallenge not required.
  • Possible
    • Time relationship reasonable but could also be explained by disease or other drugs.
    • Information may be inadequate for stronger assignment.
  • Unlikely
    • Temporal relationship makes causal link improbable.
    • Other explanations more likely.
  • Conditional / Unclassified
    • Event requires more data before assessment (pending follow-up).
  • Unassessable / Unclassifiable
    • Insufficient or contradictory information; cannot be judged.

6) Example case (walk through)

Case: 45-yr-old female started Drug A for hypertension on April 1. On April 5 she developed generalized itchy rash and facial swelling; presented to ER on April 6. She stopped Drug A on April 6; symptoms resolved over 3 days after antihistamines. No new infections, no other new meds. She had previously tolerated Drug B (another antihypertensive).

Assessment:

  • Temporality: onset 4 days after starting — plausible for hypersensitivity.
  • Dechallenge: improvement after stopping → supportive.
  • Alternative causes: none identified.
  • Prior knowledge: Drug A known to cause hypersensitivity rash (label).
  • Rechallenge: not performed (unnecessary / unethical).

WHO-UMC assignment: Probable/Likely.
Documentation: state dates, timeline, dechallenge response, absence of alternative causes, relevant literature/label citation, final category with rationale.

7) Documentation & record-keeping (what to include)

  • Final causality category and method used (e.g., WHO-UMC).
  • Short written justification: key facts (dates, dechallenge/rechallenge, labs, alternative causes).
  • Name and designation of assessor and date of assessment.
  • Any differing opinions (if multidisciplinary review).
  • If changed later (after follow-up): document the reason and date.

A typical causality note:

“WHO-UMC: Probable. AE onset 4 days after starting Drug A (2025-04-05). Symptoms improved within 3 days of stopping drug (2025-04-09). No alternative causes identified; drug labeled for hypersensitivity. Assessed by Dr. X on 2025-04-12.”

8) Regulatory implications

  • If you assign suspected causality for a serious AND unexpected event → expedited reporting (SUSAR) in many jurisdictions.
  • If causality is unlikely, may not require expedited submission but still retained in the safety database for aggregate review.

9) Special situations & nuances

  • Multiple suspect drugs: assess each drug separately; consider interactions or additive effects.
  • Class effects: if the drug is similar to others known to cause the AE, that strengthens plausibility.
  • Vaccines & immune events: timelines and biologic plausibility differ (e.g., immune thrombocytopenia).
  • Pregnancy exposures: consider maternal vs foetal events and timing of exposure.
  • Overdose / toxicity vs idiosyncratic reactions: dose–response supports causality in toxicity; idiosyncratic reactions may occur at therapeutic dose.
  • Insufficient information: mark Conditional/Unclassified and request follow-up.

10) Common pitfalls to avoid

  • Over-reliance on algorithm scores without clinical review.
  • Ignoring alternative explanations (e.g., underlying disease).
  • Using rechallenge data when rechallenge was done inadvertently but without controls — interpret cautiously.
  • Coding a causality based only on temporal association (post hoc = not necessarily causal).
  • Failing to update causality after receiving follow-up data.

11) QA, training, and SOPs

  • Organizations should define which causality method is standard (WHO-UMC common for regulatory reporting).
  • Implement peer review or consensus for borderline/serious cases.
  • Train medical reviewers with case examples and inter-rater reliability exercises.
  • Periodically audit causality assessments for consistency and quality.

12) Quick checklist for the assessor

  1. Are start/stop/onset dates present and clear?
  2. Is the temporal relationship plausible?
  3. Any dechallenge / rechallenge data?
  4. Are objective tests supportive?
  5. Alternative causes considered & documented?
  6. Is there prior information in literature/label?
  7. Which causality method used? (state clearly)
  8. Final category with succinct rationale recorded.
  9. Assessor details and date.

13) Short reference table

Evidence element

Strength for causality

Positive rechallenge (recurrence)

Very strong

Positive dechallenge (improvement)

Strong

Plausible temporal relationship

Moderate

Known ADR on label / literature

Moderate–strong

Objective lab/biopsy consistent

Strong

Alternate cause equally likely

Weakens/negates

Implausible timing

Argues against