Proposed Deceptive Ad Studies Have Little Practical Use: PhRMA

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Pharmaceutical Research and Manufacturers of America (PhRMA) says two proposed FDA studies on consumer and healthcare professional identification of false or misleading drug promotion appear to offer little practical usefulness. The association’s comment letter says that identifying deceptive promotion is FDA’s assigned responsibility and not the duty of consumers or healthcare professionals. It also says that deceptive drug promotion is not a prevalent problem that requires further studying.

“Given the agency’s regulatory requirements and current infrastructure to review promotional materials, direct-to-consumer pharmaceutical advertising is one of the most restrained and balanced forms of consumer advertising,” PhRMA says. “Research demonstrates that prescription drug promotion is overwhelmingly not deceptive, especially on Web sites and other online media.”

PhRMA also questions FDA’s assertion that one of the potential utilities of the studies is creation of a program for consumers to report deceptive prescription drug promotion to the agency since such a program already exists.

If FDA decides to proceed with the research, the letter says, PhRMA recommends consideration of several study design issues, including design of study stimuli, subject enrollment, and certain features of the study questionnaires.

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