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CHC Press Release: Comment on Social Media Draft Guidance

April 9, 2014 — The Coalition for Healthcare Communication issued the following press release today regarding the CHC Social Media ... read more

Some States Impose Reporting Requirements That Add to Sunshine Burden

April 7, 2014 – Although the Physician Payment Sunshine Act preempts state laws that require reporting of similar information required ... read more

Kamp to WSJ: FDA Could Do a Better Job of Defending Off-label Limits

March 31, 2014 – The FDA’s recent draft guidance on disseminating reprints, textbooks and clinical practice guidelines (CPGs) discussing off-label ... read more

OPDP Issues First Untitled Letter for Branded Facebook Page

March 14, 2014 – The FDA’s Office of Prescription Drug Promotion (OPDP) on Feb. 24 issued its first enforcement letter ... read more

Kamp to Speak April 2 at OPDP Enforcement Webinar

CHC Member Discount Available March 11, 2014 – Coalition for Healthcare Communication Executive John Kamp will be speaking at an ... read more

Cuts in Speaker Payments Should Be Placed in Proper Context

March 10, 2014 – The need for industry to educate the public on why company interaction with physicians is both ... read more

FDA Issues Updated Draft Guidance on Distributing Scientific and Medical Info on Unapproved New Uses

March 3, 2014 – The FDA announced today the availability of a new draft guidance (2014-04560) on distributing scientific and ... read more

New Tax Reform Legislation Includes Limit on Ad Tax Deductions

Feb. 27, 2014 – As expected, tax reform legislation introduced yesterday by Senate Ways and Means Committee Chairman Dave Camp ... read more

FDA Is Considering Shorter List of Risks in DTC TV Ad Major Statement

Feb. 17, 2014 – In recognition that the stream of risks currently disclosed on direct-to-consumer (DTC) television ads may be ... read more

OPDP Enforcement Letters Target Common Issues in Last Half of 2013

Feb. 4, 2014 — Many of the 14 enforcement letters issued by the FDA’s Office of Prescription Drug Promotion (OPDP) ... read more

Caronia Decision One Year Later: Off-label Change May Be Slow, But It’s Brewing

Jan. 27, 2014 – Although FDA officials have treated the U.S. Court of Appeals for the Second Circuit decision in ... read more

Coalition Seeks Input on FDA Online Promotion Guidance

Jan. 23, 2014 – The Coalition for Healthcare Communication would like to receive feedback from its members regarding the FDA ... read more

FDA Draft Guidance Addresses Postmarket Submission of Online Promotional Material

Jan. 14, 2014 – The determining factor regarding whether a firm submits online prescription drug promotional material to the agency ... read more

Kamp on Off-label Discussion at the CMS/FDA Summit

Jan. 3, 2014 – From Coalition for Healthcare Communication Executive Director John Kamp: Several weeks ago I was privileged to ... read more

Coalition Calls on Senators to Reject Tax on Advertising

Dec. 16, 2013 – Today the Coalition for Healthcare Communication sent a letter to U.S. Senators and Members of the ... read more

House Members Speak Out Against Inclusion of Textbooks, Reprints in Sunshine Act Reporting

Nov. 26, 2013 – On Nov. 22, 23 members of the U.S. House of Representatives sent a letter to the ... read more

OPDP Sends Warning Letter Based on Statements Made on Fast Money TV Show

Nov. 11, 2013 – The FDA Office of Prescription Drug Promotion’s (OPDP’s) recent enforcement actions – four Untitled Letters and ... read more

Physician Organizations, Medical Societies Implore HHS to Reverse Policy on Reprints and Textbooks

Oct. 28, 2013 – On Monday, 33 physician organizations and 41 national and state medical societies sent a letter to ... read more

MIWG Asks FDA to Clarify Position Regarding Manufacturer Dissemination of New Use Information

Sept. 16, 2013 – The Medical Information Working Group (MIWG), a coalition of medical product manufacturers seeking to improve the ... read more

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FDA Responds to Comments on Proposed Corrective DTC Advertising Study

Jan. 3, 2013 – In the FDA’s view, researchers and policymakers “currently lack empirical viagra online without prescription literature regarding the various influences” of corrective direct-to-consumer (DTC) advertising on prescription drug consumers. To forward the development of this literature, the FDA’s plans to conduct an experimental study on this issue are moving forward.

In a Dec. 26, 2012, Federal Register notice, the agency reiterates its corrective DTC advertising study design overview, sets forth the information collection requirements for the study, and responds to comments received on the initial study proposal published on Feb. 29, 2012.

“I’m optimistic that the FDA, like the FTC, clearly understands that ‘corrective advertising’ is an extraordinary remedy to be applied only to violations that are extraordinary,” said John Kamp, Executive Director, Coalition for Healthcare Communication.   

The study, which will

be administered over the Internet, will include 6,650 interviews of randomly assigned participants. Phase 1 of the study will vary exposure to advertising messages about asthma to examine how a combination of original and corrective DTC ads affects message recall, message comprehension, perceived drug efficacy, perceived drug risk and intentions to ask about or use the drug. Phase 2 will examine the similarity of the corrective ad’s theme and visual elements to those of the original ad for weight-loss products, as well as the exposure delay (time) between viewing the original ad and the corrective ad.

In response to a comment suggesting that the study not examine similarity and time delay but instead

evaluate “a truly informative, nondistracting, clear and conspicuous corrective ad” and “an unclear and inconspicuous corrective ad,” the FDA stated that although it appreciated the suggestion to include clarity as a variable in the study, it selected similarity and time delay as its independent variables to “provide information on the effectiveness of FDA guidance on this issue.”

Two comments also expressed concerns that the time delay conditions as proposed were not realistic and stated that a six-month time delay would be more realistic. The agency agreed that a six-month exposure delay “more closely approximates real-world exposure to original and corrective messaging” and has changed the study accordingly by embedding the stimuli in a “clutter reel” to approximate real-world experience and by adding a six-month delay condition.

The FDA concludes the notice by stating that the study was designed “to address a gap in the literature – there is scant work on the specific efficacy of televised corrective ads intended to address claims made regarding prescription drugs – rather than to simply extend and replicate past literature.”

Written comments on this notice will be accepted by the agency via fax until Jan. 25. See the Dec. 26 notice for details.canine lasix doseage