It's well known that many drug safety problems arise because people fail to take medicines as prescribed or pay attention
to warnings. Food and Drug Administration officials seek to improve communication about the risks of medical products by the
agency, industry, and interest groups through a Strategic Plan for Risk Communication unveiled September 30.
The plan outlines ways to strengthen the science behind effective risk communication on food and medical products, explained
Janet Woodcock, director of the Center for Drug Evaluation and Research (CDER), at the Food and Drug Law Institute's (FDLI)
September advertising and promotion conference. It offers specific strategies for improving risk messages and for coordinating
actions to better manage safety information, product recalls, and food safety alerts—without scaring consumers, Woodcock noted.
The last section of the plan proposes to "optimize" safety policies by taking a fresh look at FDA's legal framework for regulating
drug advertising along with labeling and sponsor interactions with health professionals. The agency wants to reassess whether
drug labeling laws designed for promotion directed at healthcare professionals fit the world of DTC advertising, or if they
foster overly technical messages that block an understanding of risk issues. FDA will weigh whether recommended changes can
be accomplished by revising current regulations, or if new legislation is needed.
If the latter, there are lots of proposals on Capitol Hill that curb drug marketing, including a ban or limit on DTC advertising
for two years after product approval. An Institute of Medicine expert panel backed such a move in its 2005 report on drug
safety, and the policy almost made it into the FDA Amendments Act of 2007 (FDAAA). The American College of Physicians recently
backed the two-year DTC ad limit, along with another IOM proposal that all new drugs carry a special "just approved" symbol
on their labels for two years to alert patients and prescribers that only limited information is available on the drug.
Other measures before Congress would require comparative effectiveness information on drug labels and ban the commercial use
of prescriber data. A drug marketing "death penalty" proposal, says attorney John Kamp, would curb DTC advertising by eliminating
the tax deduction allowed pharma companies for advertising expenditures. Even though such a policy supposedly would raise
billions to support health reform, the proposal has not gone far because of staunch opposition from broadcasters and publishers.
One Document, Please
The Strategic Plan also proposes to streamline and improve the system for providing useful written information on drug use
and side effects directly to patients. The current system is confusing and inefficient, with patient package inserts, medication
guides and other communiqués. Pharmacists evidently hand out required documents to patients, but much of the information falls
short of being "useful." Despite years of writing rules and guidances and holding public meetings on the subject, the surveys
show that consumers don't read the information they get and don't understand what they do read.
FDA weighed new options at a two-day workshop in September on promoting patient access to timely and accurate information
on drug risks. The current thinking is to replace the various hand-outs with a single standard document for communicating
"essential information" about prescription drugs. That concept has considerable appeal, but still raises questions about which
drugs warrant special consumer information and how to make the documents useful and readable. Manufacturers have long objected
to requiring written information on all drugs, and pharmacists don't want more pieces of paper to store, track, and distribute.
One solution is to provide the information electronically, but pharma companies are nervous about third parties changing content
and language in the process. For now, FDA plans more studies on the format and content of written patient information, and
more discussion to follow.
The value and content of written consumer information on drugs has become a hot-button issue as FDA establishes more Risk
Mitigation and Evaluation Strategies (REMS) that require distribution of these documents. FDA has approved 63 new REMS in
the last two years, Woodcock noted at the FDA Regulatory and Compliance Symposium in September. Of those, 47 require MedGuides,
while the others involve more restrictive risk management programs. CDER now seems to require some kind of REMS for most new
molecular entities, and that trend promises to greatly expand written patient information.
A one-document policy for drug handouts may inform ongoing efforts to revise the brief summary of risk information required
in print drug ads. The conventional wisdom is that this document is neither "brief" nor an informative summary, and that it
needs a complete makeover to be a more useful tool. CDER's Division of Drug Marketing, Advertising and Communications (DDMAC)
has been examining brief summary options for years and continues to test patient response and comprehension of different formats,
reported Helen Sullivan of DDMAC's research team at the FDLI conference. Pollsters evidently are asking overweight people
in shopping malls to look at different types of ads with brief summaries for a fictitious diet drug and indicate which format
they like and understand the best. A design that resembles the "drug facts" label for over-the-counter drugs seems to come
out on top, but the old dense format doesn't do too badly either.