Stakeholders Question Healthcare Professional Survey
Three stakeholders are raising questions about proposed FDA research surveying healthcare professionals on prescription drug promotion. Pharmaceutical Research and Manufacturers of America (PhRMA) says the agency has not followed Paperwork Reduction Act (PRA) procedures that require it to provide adequate means to request and obtain a copy of the survey. “Before FDA can go forward with its survey,” PhRMA says, “the PRA requires FDA to issue a new 60-day notice that complies with the PRA and applicable regulations. The new notice should provide an adequate mechanism for the public to obtain without charge the actual survey and its related instructions, and not just the general summary of its research goals in the Federal Register.”
PhRMA also complains that the proposed survey duplicates information otherwise reasonably accessible to the agency. If FDA goes forward with its proposal, the trade group says, it should modify the survey’s questions on opioid issues. Rather than only inquiring about abuse-deterrent formulations, it says, FDA should also ask about alternatives to opioids and other tools to address the opioid crisis. PhRMA also offers specific comments on the proposed survey questions to provide clarity and better align the questions with the research’s stated purpose.
UnitedHealth Group asks FDA to consider including survey questions on how promotional materials and procedures address abuse-deterrence formulations for opioid products. It also suggests the inclusion of questions related to marketing of abuse-deterrent formulations of opioid products to ensure that providers understand that: abuse-deterrent formulated products have not proven any less addictive that standard formulations, the potential for patient harm from dose-dependent misuse of abuse-deterrent formulated products remains, potential methods for defeating the “tamper-proof” formulation still exist, and there are effective ways to protect against accidental ingestion of the drug or theft by others.
Lilly provides comments on the study methodology and objectives and also on the study questionnaire.