‘Concerning’ DTC Ad Misbrands Hizentra: FDA
A direct-to-consumer TV ad for CSL Behring’s Hizentra (immune globulin subcutaneous (human)) overstates the drug’s effectiveness and minimizes safety information, thus misbranding it, according to a CBER Warning Letter. The letter says the Hizentra labeling describes it as a 20% liquid subcutaneous immune globulin indicated to treat primary humoral immunodeficiency in adults and pediatric patients two years of age and older, and chronic inflammatory demyelinating polyneuropathy in adults, as a maintenance therapy or to prevent relapse of neuromuscular disability and impairment.
Hizentra has a Boxed Warning about the potential of thrombosis, CBER says, and also has Contraindications, Precautions, and Warnings.
The letter describes elements of the ad that CBER says overstate its effectiveness and minimize the safety information, and says they are concerning from a public health standpoint because the ad creates the misleading impression that Hizentra is more effective than has been demonstrated by substantial evidence and minimizes the risks of treatment with the product.
CSL Behring was told to respond with a list of all Hizentra promotions that contain representations such as those described in the letter and a plan to discontinue such communications or to cease distributing the drug. The company is also to submit a comprehensive plan of action to disseminate truthful, non-misleading, and complete corrective communications about the concerns discussed in the letter to the audiences that received the violative promotions.