‘Off-Label’ Communications Q&A Guide
FDA has approved a guidance, Communications from Firms to Healthcare Providers Regarding Scientific Information on Unapproved Uses of Approved/Cleared Medical Products: Questions and Answers, to reassure firms that if they provide communications that are consistent with the guidance’s recommendations, the agency will not consider the dissemination of such communication standing alone as evidence of a new intended use for the product. The document also says FDA does not expect a firm to submit such a communication to it at the time the communication is initially shared with healthcare providers (HCPs).
The enforcement approach outlined in the guidance, FDA says, has as a key tenet that to promote the public health, any individual firm-initiated communication of scientific information about unapproved uses of the firm’s approved/cleared medical products should be truthful and non-misleading and should provide and appropriately present all information necessary for HCPs to understand and evaluate the strengths and weaknesses, validity, and clinical utility of the scientific information on unapproved uses in the specific communication. It says the guidance recommendations are consistent with these principles.
The guidance specifies the types of source materials that companies may use for their communications under the enforcement policy.
FDA says that in developing the guidance it considered feedback from interested parties, including comments received on a revised draft guidance from 2023. This guidance finalizes the 2023 draft, it says.