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# Proposed FDA Advertising Research Often Unneeded: PhRMA
- URL: https://www.fdaweb.com/proposed-fda-advertising-research-often-unneeded-phrma/
- Published: 2017-08-16T12:00:00.000Z
- Updated: 2026-09-14T22:41:32.000Z
- Author: David McFarland
- Tags: FDA Policy/General, #legacy-id-D5139400

Pharmaceutical Research and Manufacturers of America (PhRMA) says it supports substantive research focused on prescription drug advertising and promotion, but is concerned with FDA’s recent approaches to studies in this area. In a [letter](https://www.regulations.gov/contentStreamer?documentId=FDA-2017-N-0558-0006&attachmentNumber=1&contentType=pdf&ref=fdaweb.com) commenting on an agency proposal to study disclosures in professional and consumer prescription drug promotion, PhRMA says FDA “has proposed to undertake projects in a variety of disparate topics without articulating a clear, overarching research agenda or adequate rationale on how the proposed research related to the goal of further protecting public health. … At times, FDA proposes new studies seemingly without fully appreciating its own previous research. We suggest that the agency publish a comprehensive list of its prescription drug advertising and promotion studies from the past five years and articulate a clear vision for its research priorities for the near future.”

Two issues PhRMA addresses in its specific comments are: 

- disclosures is an important topic that should be properly researched, particularly in light of First Amendment considerations and the potential for disclosures to enable a broader range of manufacturer communications; and
- if FDA decides to proceed with the research, it should consider several study designs to enhance the quality, utility, and clarity of the information to be collected.