Comments on OPDP Quantitative Claims Research

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Novartis says FDA research into quantitative claims in direct-to-consumer (DTC) prescription drug ads could be improved if the examples drawn from DTC ads in the marketplace could include for testing some examples of ads that are consistent with FDA product labeling. The company’s comment letter also says that consumer comprehension may be influenced by health status. Since individuals with a health condition or their caregivers are the intended target of DTC prescription drug advertising, it says, “it would be important to ensure that adequate numbers of such individuals are recruited to provide more meaningful results.”

The National Center for Health Research says it strongly recommends that determining patients’ and consumers’ comprehension of information about the relative risk, absolute risk, relative benefit, and absolute benefit of a drug should also be evaluated by the CDER Office of Prescription Drug Promotion in this research. It also asks that FDA be more specific about the number of interviews it plans to conduct to compile the desired information and what type of demographic diversity the agency will require when selecting people to be interviewed. “A relatively small or homogeneous selection of individuals to interview one-on-one could result in unintentional bias in the survey, which in turn would have implications for the results of the estimated 1,100 completed surveys,” the letter says.

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