Industry Faults FDA Research on DTC ‘Implied Claims’

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Pharmaceutical Research and Manufacturers of America (PhRMA) says it is concerned that research proposed by the CDER Office of Prescription Drug Promotion (OPDP) on implied claims in direct-to-consumer (DTC) drug promotions “lacks practical utility.” The association’s comment letter says it is not clear what the agency intends to do with the research findings and whether or how the research might inform FDA’s regulatory oversight. PhRMA also says FDA has not explained why new research is needed on whether claims can result in a misleading impression.

PhRMA also questions whether the mock ads proposed for the study will have clear and specific implied claims amenable to testing. It recommends that FDA provide the mock ads for public review and comment before moving ahead with the proposed research.

If the agency decides to continue with the research, PhRMA provides recommendations that it says will enhance the quality, utility, and clarity of the survey.

In its comment, AbbVie calls on OPDP to provide the explicit and implied claims that will be used in the research’s mock ads and the 13 characteristics that will be assessed during the conjoint analysis. It also gives specific recommendations on some of the survey questions.

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