Stakeholders Question Disease Awareness Ad Research

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AbbVie says it is unclear why FDA considers proposed research into disease awareness versus product-specific television ads to be a priority for the public health such that the study is necessary. In comments on the agency’s proposed research, the company reviews agency and industry efforts to regulate advertising. If the agency intends to carry out the research, it says, testing of mock ads for non-existing products in an artificial environment is not likely to produce meaningful results. AbbVie suggests specific items for FDA to consider should it intend to proceed with the research.

Pharmaceutical Research and Manufacturers of America (PhRMA) says FDA should establish a clear, over-arching agenda for its research to help ensure that all of its research constitutes useful and non-duplicative collection of information. It also calls on FDA to publish a comprehensive list of its prescription drug advertising and promotion studies from recent years and articulate its research priorities for the near future in light of its completed and ongoing research. “Going forward, FDA should use such priorities to confirm the necessity and utility of its proposed research and to ensure proposed information collections serve as meaningful extensions of the agency’s ongoing research efforts.” The trade group’s comments address the role of disease awareness communications, the fact that the proposed study appears to duplicate prior FDA studies, and opportunities for improvement of the quality, utility, and clarity of the information collected if FDA proceeds with the study.

Bayer says that since companies can’t control how often a consumer will view a disease awareness communication, there is limited utility to researching the impact of the number of exposures. And, it says, since companies cannot control if a consumer will see a promotional ad one day or one week after seeing a disease awareness ad, there appears to be limited utility in researching the impact of the temporal separation. It suggests modification to the number of proposed studies and the study design.

Finally, Lilly says it supports an evidence-based approach to regulation of drug sponsor communications and supports FDA efforts to encourage disease awareness communications. The company provides several specific comments on the proposed research design.

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