Agency Information Collection Activities; Proposed Collection; Comment Request; Impact of Coupons on Consumer Perceptions of Products in Prescription Drugs in Direct-to-Consumer Prescription Drug Print Advertisements, 6077-6079 [E6-1521]
Download as PDF
6077
Federal Register / Vol. 71, No. 24 / Monday, February 6, 2006 / Notices
requirements for nutrient content
claims.
FDA estimates the burden of this
collection of information as follows:
TABLE 1.—ESTIMATED ANNUAL REPORTING BURDEN1
Type of survey
Annual frequency
per response
Number of respondents
Internet Survey
2880
Total annual responses
Hours per response
Total hours
2880
.25
720
1
Total
720
1 There
are no capital costs or operating and maintenance costs associated with this collection of information.
approval expires on January 31, 2009. A
copy of the supporting statement for this
information collection is available on
the Internet at https://www.fda.gov/
ohrms/dockets.
FDA’s burden estimate is based on
prior experience with Internet panel
experiments similar to the study
proposed here.
Dated: January 30, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6–1517 Filed 2–3–06; 8:45 am]
Dated: January 30, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6–1518 Filed 2–3–06; 8:45 am]
BILLING CODE 4160–01–S
BILLING CODE 4160–01–S
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
Agency Information Collection
Activities; Announcement of Office of
Management and Budget Approval;
Record Retention Requirements for the
Soy Protein and Risk of Coronary
Heart Disease Health Claim
Food and Drug Administration,
HHS.
ACTION:
Notice.
The Food and Drug
Administration (FDA) is announcing
that a collection of information entitled
‘‘Record Retention Requirements for the
Soy Protein and Risk of Coronary Heart
Disease Health Claim’’ has been
approved by the Office of Management
and Budget (OMB) under the Paperwork
Reduction Act of 1995.
FOR FURTHER INFORMATION CONTACT:
Jonna Capezzuto, Office of Management
Programs (HFA–250), Food and Drug
Administration, 5600 Fishers Lane,
Rockville, MD 20857, 301–827–4659.
SUPPLEMENTARY INFORMATION: In the
Federal Register of November 15, 2005
(FR 70 69344), the agency announced
that the proposed information collection
had been submitted to OMB for review
and clearance under 44 U.S.C. 3507. An
agency may not conduct or sponsor, and
a person is not required to respond to,
a collection of information unless it
displays a currently valid OMB control
number. OMB has now approved the
information collection and has assigned
OMB control number 0910–0428. The
rmajette on PROD1PC67 with NOTICES1
SUMMARY:
VerDate Aug<31>2005
14:55 Feb 03, 2006
Dated: January 30, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6–1519 Filed 2–3–06; 8:45 am]
BILLING CODE 4160–01–S
Food and Drug Administration
[Docket No. 2005N–0317]
AGENCY:
displays a currently valid OMB control
number. OMB has now approved the
information collection and has assigned
OMB control number 0910–0572. The
approval expires on January 31, 2009. A
copy of the supporting statement for this
information collection is available on
the Internet at https://www.fda.gov/
ohrms/dockets.
Jkt 208001
[Docket No. 2000N–1269] (formerly Docket
No. 00N–1269)
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Agency Information Collection
Activities; Announcement of Office of
Management and Budget Approval;
Requirements on Content and Format
of Labeling for Human Prescription
Drugs and Biologics; Requirements for
Prescription Drug Product Labels
Food and Drug Administration
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice.
SUMMARY: The Food and Drug
Administration (FDA) is announcing
that a collection of information entitled
‘‘Requirements on Content and Format
of Labeling for Human Prescription
Drugs and Biologics; Requirements for
Prescription Drug Product Labels’’ has
been approved by the Office of
Management and Budget (OMB) under
the Paperwork Reduction Act of 1995.
FOR FURTHER INFORMATION CONTACT:
Karen Nelson, Office of Management
Programs (HFA–250), Food and Drug
Administration, 5600 Fishers Lane,
Rockville, MD 20857, 301–827–1482.
SUPPLEMENTARY INFORMATION: In the
Federal Register of December 22, 2000
(65 FR 81082), the agency announced
that the proposed information collection
had been submitted to OMB for review
and clearance under 44 U.S.C. 3507. An
agency may not conduct or sponsor, and
a person is not required to respond to,
a collection of information unless it
PO 00000
Frm 00045
Fmt 4703
Sfmt 4703
[Docket No. 2006N–0029]
Agency Information Collection
Activities; Proposed Collection;
Comment Request; Impact of Coupons
on Consumer Perceptions of Products
in Prescription Drugs in Direct-toConsumer Prescription Drug Print
Advertisements
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice.
SUMMARY: The Food and Drug
Administration (FDA) is announcing an
opportunity for public comment on a
proposed collection of certain
information by the agency. Under the
Paperwork Reduction Act of 1995 (the
PRA), Federal agencies are required to
publish notice in the Federal Register
concerning each proposed collection of
information and to allow 60 days for
public comment in response to the
notice. This notice solicits comments on
a study of the impact of coupons (such
as price incentives or rebate offers) on
consumers’ perceptions of product risks
and benefits in direct-to-consumer
(DTC) print ads.
DATES: Submit written or electronic
comments on the collection of
information by April 7, 2006.
E:\FR\FM\06FEN1.SGM
06FEN1
6078
Federal Register / Vol. 71, No. 24 / Monday, February 6, 2006 / Notices
Submit electric comments
on the collection of information to:
https://www.accessdata.fda.gov/scripts/
oc/dockets/edockethome.cfm. Submit
written comments on the collection of
information to the Division of Dockets
Management (HFA–305), Food and Drug
Administration, 5630 Fishers Lane, rm.
1061, Rockville, MD 20852. All
comments should be identified with the
docket number found in brackets in the
heading of this document.
FOR FURTHER INFORMATION CONTACT:
Karen Nelson, Office Management
Programs (HFA–250), Food and Drug
Administration, 5600 Fishers Lane,
Rockville, MD 20857, 301–827–1482.
SUPPLEMENTARY INFORMATION: Under the
PRA (44 U.S.C. 3501–3520), Federal
agencies must obtain approval from the
Office of Management and Budget
(OMB) for each collection of
information they conduct or sponsor.
‘‘Collection of information’’ is defined
in 44 U.S.C. 3502(3) and 5 CFR
1320.3(c) and includes agency requests
or requirements that members of the
public submit reports, keep records, or
provide information to a third party.
Section 3506(c)(2)(A) of the PRA (44
U.S.C. 3506(c)(2)(A)) requires Federal
agencies to provide a 60-day notice in
the Federal Register concerning each
proposed collection of information,
including each proposed extension of an
existing collection of information,
before submitting the collection to OMB
for approval. To comply with this
requirement, FDA is publishing notice
of the proposed collections of
information set forth in this document.
With respect to each of the following
collections of information, FDA invites
comments on: (1) Whether the proposed
collection of information is necessary
for the proper performance of FDA’s
functions, including whether the
information will have practical utility;
(2) the accuracy of FDA’s estimate of the
burden of the proposed collection of
information, including the validity of
the methodology and assumptions used;
(3) ways to enhance the quality, utility,
and clarity of the information to be
collected; and (4) ways to minimize the
burden of the collection of information
on respondents, including through the
use of automated collection techniques,
when appropriate, and other forms of
information technology.
rmajette on PROD1PC67 with NOTICES1
ADDRESSES:
Impact of Coupons on Consumer
Perceptions of Products in Direct-toConsumer Prescription Drug Print
Advertisements
The Federal Food, Drug, and Cosmetic
Act (the act) requires that
manufacturers, packers, and distributors
VerDate Aug<31>2005
14:55 Feb 03, 2006
Jkt 208001
(sponsors) who advertise prescription
human and animal drugs, including
biological products for humans, disclose
in advertisements certain information
about the advertised product’s uses and
risks. For prescription drugs and
biologics, the act requires
advertisements to contain ‘‘information
in brief summary relating to side effects,
contraindications, and effectiveness’’
(21 U.S.C. 352(n)). FDA is responsible
for enforcing the act and implementing
regulations.
FDA regulations require that
prescription drug advertisements that
make claims about a product must also
include risk information in a
‘‘balanced’’ manner (21 CFR
202.1(e)(5)(ii)), both in terms of the
content and presentation of the
information. Advertisements that draw
attention to the name of the product but
do not make representations about the
product’s indication(s) or dosage
recommendations are called reminder
advertisements. Reminder ads may
mention the proprietary and established
name of the product and (optionally)
contain information about the product’s
ingredients, dosage form, quantity,
price, or manufacturer (21 CFR
202.1(e)(2)(i)). Graphic presentation and
information is not prohibited in
reminder ads as long as that information
does not make a representation or
suggestion about the product beyond
those permitted.
The exemption for reminder ads was
originally intended to allow distribution
of price sheets, pens, notepads and
other minor giveaways featuring the
name of the drug product to physicians
and other healthcare professionals
without requiring a full disclosure of the
product’s risks. As DTC promotion has
increased, sponsors have chosen to
create reminder ads for consumers.
Sponsors may use ads as a vehicle to
offer price incentives or coupons to
consumers (e.g., ‘‘free trial,’’ ‘‘buy six
get one free’’). Coupon promotions are
widely used in many product categories
and have been the topic of many
academic studies. Coupons are
primarily offered to increase the sales of
the brand relative to their level without
coupons.1 Certain types of coupons,
most notably those that appear in the
body of an advertisement itself, can
positively impact perceptions of the
brand.
People tend to rate owned objects
more favorably than those they do not
own, even when those objects have been
1 LeClerc, France and John D.C. Little ‘‘Can
advertising copy make FSI coupons more
effective?’’ Journal of Marketing Research, 34(4),
473-484, 1997.
PO 00000
Frm 00046
Fmt 4703
Sfmt 4703
assigned to them at random.2 This has
been termed the ‘‘mere ownership’’ or
‘‘mere possession’’ effect. An interesting
extension of this effect is provided in
research by Sen and Johnson 3 which
has shown that consumers rate a
product more favorably when they are
simply given a gift certificate or a
coupon for that product or service.
Other research has examined the effect
of warranties. People who viewed an ad
with a high warranty perceived the
product as being less risky compared to
people who saw an ad with a medium
or low warranty.4
Based on this body of consumer
research, the inclusion of coupons or
other price incentives in DTC ads may
impact consumers’ perceptions of the
risks and benefits of the prescription
drug. For ‘‘simple’’ consumer products,
coupons and free trial offers may enable
the customer to test new products while
minimizing their financial risk of testing
the product. For products that
consumers can readily test and ones
where performance can be adequately
verified (termed ‘‘search’’ goods by
economists), coupons and free trial
offers provide both the consumer and
manufacturer an efficient mechanism
for matching consumers and products.
For more complex products such as
prescription drugs where supervision of
a physician is required to evaluate both
appropriateness and performance,
coupons and free trial offers may send
different signals. These signals may
foster consumer misperceptions about
the advertised prescription drug product
by exploiting general beliefs. Thus,
prescription drugs promoted with
coupons or free trial offers may be seen
as more widely indicated, more
appropriate and/or less risky than they
really are. Inclusion of a mechanism
that affects consumers’ perception of the
product’s risks is especially problematic
in reminder ads because this type of ad
contains no accompanying risk
information. Furthermore, coupons and
price promotions may imply superior
drug efficacy.
The proposed study will examine the
impact coupons have on consumers’
perceptions of risks and benefits and the
overall impression of the product in
DTC full-product and reminder
2 Beggan, James K., ‘‘On the social nature of
nonsocial perception: The mere ownership effect,’’
Journal of Personality and Social Psychology, 62(2),
229-237, 1992.
3 Sen, Sankar and Eric J. Johnson, ‘‘Merepossession effects without possession in consumer
choice,’’ Journal of Consumer Research, 24 (June),
105-117, 1997.
4 Shimp, Terrence A. and William O. Bearden,
‘‘Warranty and other extrinsic cue effects on
consumers’ risk perceptions,’’ Journal of Consumer
Research, 9 (June), 38-47, 1982.
E:\FR\FM\06FEN1.SGM
06FEN1
6079
Federal Register / Vol. 71, No. 24 / Monday, February 6, 2006 / Notices
advertisements. To justify future
regulatory changes, we need to have
better empirical data about consumers’
perceptions of the information in both
types of ads and how inclusion of such
promotional devices can impact
consumers’ perceptions of the risks and
benefits of advertised prescription
drugs.
Design Overview: This study will
employ a between-subjects crossed
factorial design and will focus on
consumer print advertising. Fifteen
print advertisements will be created
using three levels of ad type and five
levels of promotional offer. Thus, the
factors will be ad type (DTC print
reminder; DTC print full product; overthe-counter print full product) and offer
type (free trial offer; buy one, get one
free; money off prescription/purchase
cost; money back guarantee; no
promotion). Product name and
indication will be constant across
conditions. Side effect and risk
information will be constant across full
product DTC ad conditions. Participants
will be asked to read a single print
advertisement for a new drug. After
reading the advertisement, they will be
asked questions about their evaluation
of the information presented in the
advertisement.
Factors: (1) Participants. Consumers
will be screened and recruited by the
contractor to be currently diagnosed
with insomnia or at risk of developing
insomnia. Participants will be randomly
assigned to experimental cells. Each
one, get one free, these are promotional
variations that have been used in drug
advertising. We ask for comment on
other promotional types that could be
tested.
Procedure: Participants will be shown
one ad, for example, a reminder ad for
a prescription drug with a free-trial offer
coupon attached. Then the participant
will be asked to answer questions
examining a number of important
perceptions about the product,
including perceived riskiness of the
drug, likelihood of benefits, and
behavioral intent (talking to doctor,
product purchase). Finally,
demographic and health care utilization
information will be collected.
Interviews are expected to last
approximately 15 minutes. A total of
1,350 participants will be involved. This
will be a one time (rather than annual)
collection of information.
FDA estimates the burden of this
collection of information as follows:
FDA estimates that 2,025 individuals
will need to be screened to obtain a
respondent sample of 1,350. The
screener is expected to take 30 seconds,
for a total screener burden of 17 hours.
The 1,350 respondents will then be
asked to respond to a series of questions
about the advertisement. We estimate
the response burden for the consumer
part of the survey to be 15 minutes, for
a burden of 337.5 hours. The estimated
total burden for this data collection
effort is 354.5 hours. The respondent
burden chart is listed below:
condition will be balanced with respect
to gender.
Because this is the first investigation
of this issue with DTC ads, we chose to
limit our investigation to one disease
condition. We chose to accept this
decrease in generality to maximize our
ability to detect a subtle difference
between promotion types. Participants
will be screened to represent a range of
education levels (some college or less
vs. completed college or more). Because
the task presumes basic reading
abilities, all participants will have
English as their primary language and,
as appropriate, be required to have
reading glasses when participating in
the study.
(2) Type of Ad. Three types of ads will
be tested: A full-product ad for a
prescription drug, a reminder ad for a
prescription drug, and an ad for an overthe-counter (OTC) drug. An ad for an
OTC drug, which typically includes
benefit but not risk information, is
included to see if prior research findings
in the area of consumer package goods
can be replicated. It is expected that
consumer processing of information in
the ad may vary by presence of a
promotion. For instance, consumers
may assign more weight to benefit
claims in cases where a promotional
coupon is included.
(3) Type of Promotion. Five types of
promotion will be tested: Free trial offer,
buy one, get one free, money-off
prescription/purchase cost, money back
guarantee, and a no promotion
condition. With the exception of buy
ESTIMATED ANNUAL REPORTING BURDEN
Annual frequency
per response
No. of respondents
Total annual
responses
Hours per
response
Total hours
2,025 (screener)
1
2,025
.008
17
1,350 (questionnaire)
1
1,350
.25
337.5
Total
3,375
354.5
Footnote: there are no capital costs or operating and maintenance costs associated with this data collection.
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
BILLING CODE 4160–01–S
rmajette on PROD1PC67 with NOTICES1
Dated: January 30, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6–1521 Filed 2–3–06; 8:45 am]
[Docket No. 2006N–0036]
Food and Drug Administration
Agency Information Collection
Activities; Proposed Collection;
Comment Request; Experimental
Study of Possible Footnotes and
Cueing Schemes to Help Consumers
Interpret Quantitative Trans Fat
Disclosure on the Nutrition Facts Panel
AGENCY:
Food and Drug Administration,
HHS.
VerDate Aug<31>2005
14:55 Feb 03, 2006
Jkt 208001
PO 00000
Frm 00047
Fmt 4703
Sfmt 4703
ACTION:
Notice.
SUMMARY: The Food and Drug
Administration (FDA) is announcing an
opportunity for public comment on the
proposed collection of certain
information by the agency. Under the
Paperwork Reduction Act of 1995 (the
PRA), Federal agencies are required to
publish notice in the Federal Register
concerning each proposed collection of
information, including each proposed
reinstatement of an existing collection
of information, and to allow 60 days for
public comment in response to the
notice. This notice solicits comments on
E:\FR\FM\06FEN1.SGM
06FEN1
Agencies
[Federal Register Volume 71, Number 24 (Monday, February 6, 2006)]
[Notices]
[Pages 6077-6079]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-1521]
-----------------------------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. 2006N-0029]
Agency Information Collection Activities; Proposed Collection;
Comment Request; Impact of Coupons on Consumer Perceptions of Products
in Prescription Drugs in Direct-to-Consumer Prescription Drug Print
Advertisements
AGENCY: Food and Drug Administration, HHS.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Food and Drug Administration (FDA) is announcing an
opportunity for public comment on a proposed collection of certain
information by the agency. Under the Paperwork Reduction Act of 1995
(the PRA), Federal agencies are required to publish notice in the
Federal Register concerning each proposed collection of information and
to allow 60 days for public comment in response to the notice. This
notice solicits comments on a study of the impact of coupons (such as
price incentives or rebate offers) on consumers' perceptions of product
risks and benefits in direct-to-consumer (DTC) print ads.
DATES: Submit written or electronic comments on the collection of
information by April 7, 2006.
[[Page 6078]]
ADDRESSES: Submit electric comments on the collection of information
to: https://www.accessdata.fda.gov/scripts/oc/dockets/edockethome.cfm.
Submit written comments on the collection of information to the
Division of Dockets Management (HFA-305), Food and Drug Administration,
5630 Fishers Lane, rm. 1061, Rockville, MD 20852. All comments should
be identified with the docket number found in brackets in the heading
of this document.
FOR FURTHER INFORMATION CONTACT: Karen Nelson, Office Management
Programs (HFA-250), Food and Drug Administration, 5600 Fishers Lane,
Rockville, MD 20857, 301-827-1482.
SUPPLEMENTARY INFORMATION: Under the PRA (44 U.S.C. 3501-3520), Federal
agencies must obtain approval from the Office of Management and Budget
(OMB) for each collection of information they conduct or sponsor.
``Collection of information'' is defined in 44 U.S.C. 3502(3) and 5 CFR
1320.3(c) and includes agency requests or requirements that members of
the public submit reports, keep records, or provide information to a
third party. Section 3506(c)(2)(A) of the PRA (44 U.S.C. 3506(c)(2)(A))
requires Federal agencies to provide a 60-day notice in the Federal
Register concerning each proposed collection of information, including
each proposed extension of an existing collection of information,
before submitting the collection to OMB for approval. To comply with
this requirement, FDA is publishing notice of the proposed collections
of information set forth in this document.
With respect to each of the following collections of information,
FDA invites comments on: (1) Whether the proposed collection of
information is necessary for the proper performance of FDA's functions,
including whether the information will have practical utility; (2) the
accuracy of FDA's estimate of the burden of the proposed collection of
information, including the validity of the methodology and assumptions
used; (3) ways to enhance the quality, utility, and clarity of the
information to be collected; and (4) ways to minimize the burden of the
collection of information on respondents, including through the use of
automated collection techniques, when appropriate, and other forms of
information technology.
Impact of Coupons on Consumer Perceptions of Products in Direct-to-
Consumer Prescription Drug Print Advertisements
The Federal Food, Drug, and Cosmetic Act (the act) requires that
manufacturers, packers, and distributors (sponsors) who advertise
prescription human and animal drugs, including biological products for
humans, disclose in advertisements certain information about the
advertised product's uses and risks. For prescription drugs and
biologics, the act requires advertisements to contain ``information in
brief summary relating to side effects, contraindications, and
effectiveness'' (21 U.S.C. 352(n)). FDA is responsible for enforcing
the act and implementing regulations.
FDA regulations require that prescription drug advertisements that
make claims about a product must also include risk information in a
``balanced'' manner (21 CFR 202.1(e)(5)(ii)), both in terms of the
content and presentation of the information. Advertisements that draw
attention to the name of the product but do not make representations
about the product's indication(s) or dosage recommendations are called
reminder advertisements. Reminder ads may mention the proprietary and
established name of the product and (optionally) contain information
about the product's ingredients, dosage form, quantity, price, or
manufacturer (21 CFR 202.1(e)(2)(i)). Graphic presentation and
information is not prohibited in reminder ads as long as that
information does not make a representation or suggestion about the
product beyond those permitted.
The exemption for reminder ads was originally intended to allow
distribution of price sheets, pens, notepads and other minor giveaways
featuring the name of the drug product to physicians and other
healthcare professionals without requiring a full disclosure of the
product's risks. As DTC promotion has increased, sponsors have chosen
to create reminder ads for consumers.
Sponsors may use ads as a vehicle to offer price incentives or
coupons to consumers (e.g., ``free trial,'' ``buy six get one free'').
Coupon promotions are widely used in many product categories and have
been the topic of many academic studies. Coupons are primarily offered
to increase the sales of the brand relative to their level without
coupons.\1\ Certain types of coupons, most notably those that appear in
the body of an advertisement itself, can positively impact perceptions
of the brand.
---------------------------------------------------------------------------
\1\ LeClerc, France and John D.C. Little ``Can advertising copy
make FSI coupons more effective?'' Journal of Marketing Research,
34(4), 473-484, 1997.
---------------------------------------------------------------------------
People tend to rate owned objects more favorably than those they do
not own, even when those objects have been assigned to them at
random.\2\ This has been termed the ``mere ownership'' or ``mere
possession'' effect. An interesting extension of this effect is
provided in research by Sen and Johnson \3\ which has shown that
consumers rate a product more favorably when they are simply given a
gift certificate or a coupon for that product or service. Other
research has examined the effect of warranties. People who viewed an ad
with a high warranty perceived the product as being less risky compared
to people who saw an ad with a medium or low warranty.\4\
---------------------------------------------------------------------------
\2\ Beggan, James K., ``On the social nature of nonsocial
perception: The mere ownership effect,'' Journal of Personality and
Social Psychology, 62(2), 229-237, 1992.
\3\ Sen, Sankar and Eric J. Johnson, ``Mere-possession effects
without possession in consumer choice,'' Journal of Consumer
Research, 24 (June), 105-117, 1997.
\4\ Shimp, Terrence A. and William O. Bearden, ``Warranty and
other extrinsic cue effects on consumers' risk perceptions,''
Journal of Consumer Research, 9 (June), 38-47, 1982.
---------------------------------------------------------------------------
Based on this body of consumer research, the inclusion of coupons
or other price incentives in DTC ads may impact consumers' perceptions
of the risks and benefits of the prescription drug. For ``simple''
consumer products, coupons and free trial offers may enable the
customer to test new products while minimizing their financial risk of
testing the product. For products that consumers can readily test and
ones where performance can be adequately verified (termed ``search''
goods by economists), coupons and free trial offers provide both the
consumer and manufacturer an efficient mechanism for matching consumers
and products. For more complex products such as prescription drugs
where supervision of a physician is required to evaluate both
appropriateness and performance, coupons and free trial offers may send
different signals. These signals may foster consumer misperceptions
about the advertised prescription drug product by exploiting general
beliefs. Thus, prescription drugs promoted with coupons or free trial
offers may be seen as more widely indicated, more appropriate and/or
less risky than they really are. Inclusion of a mechanism that affects
consumers' perception of the product's risks is especially problematic
in reminder ads because this type of ad contains no accompanying risk
information. Furthermore, coupons and price promotions may imply
superior drug efficacy.
The proposed study will examine the impact coupons have on
consumers' perceptions of risks and benefits and the overall impression
of the product in DTC full-product and reminder
[[Page 6079]]
advertisements. To justify future regulatory changes, we need to have
better empirical data about consumers' perceptions of the information
in both types of ads and how inclusion of such promotional devices can
impact consumers' perceptions of the risks and benefits of advertised
prescription drugs.
Design Overview: This study will employ a between-subjects crossed
factorial design and will focus on consumer print advertising. Fifteen
print advertisements will be created using three levels of ad type and
five levels of promotional offer. Thus, the factors will be ad type
(DTC print reminder; DTC print full product; over-the-counter print
full product) and offer type (free trial offer; buy one, get one free;
money off prescription/purchase cost; money back guarantee; no
promotion). Product name and indication will be constant across
conditions. Side effect and risk information will be constant across
full product DTC ad conditions. Participants will be asked to read a
single print advertisement for a new drug. After reading the
advertisement, they will be asked questions about their evaluation of
the information presented in the advertisement.
Factors: (1) Participants. Consumers will be screened and recruited
by the contractor to be currently diagnosed with insomnia or at risk of
developing insomnia. Participants will be randomly assigned to
experimental cells. Each condition will be balanced with respect to
gender.
Because this is the first investigation of this issue with DTC ads,
we chose to limit our investigation to one disease condition. We chose
to accept this decrease in generality to maximize our ability to detect
a subtle difference between promotion types. Participants will be
screened to represent a range of education levels (some college or less
vs. completed college or more). Because the task presumes basic reading
abilities, all participants will have English as their primary language
and, as appropriate, be required to have reading glasses when
participating in the study.
(2) Type of Ad. Three types of ads will be tested: A full-product
ad for a prescription drug, a reminder ad for a prescription drug, and
an ad for an over-the-counter (OTC) drug. An ad for an OTC drug, which
typically includes benefit but not risk information, is included to see
if prior research findings in the area of consumer package goods can be
replicated. It is expected that consumer processing of information in
the ad may vary by presence of a promotion. For instance, consumers may
assign more weight to benefit claims in cases where a promotional
coupon is included.
(3) Type of Promotion. Five types of promotion will be tested: Free
trial offer, buy one, get one free, money-off prescription/purchase
cost, money back guarantee, and a no promotion condition. With the
exception of buy one, get one free, these are promotional variations
that have been used in drug advertising. We ask for comment on other
promotional types that could be tested.
Procedure: Participants will be shown one ad, for example, a
reminder ad for a prescription drug with a free-trial offer coupon
attached. Then the participant will be asked to answer questions
examining a number of important perceptions about the product,
including perceived riskiness of the drug, likelihood of benefits, and
behavioral intent (talking to doctor, product purchase). Finally,
demographic and health care utilization information will be collected.
Interviews are expected to last approximately 15 minutes. A total of
1,350 participants will be involved. This will be a one time (rather
than annual) collection of information.
FDA estimates the burden of this collection of information as
follows:
FDA estimates that 2,025 individuals will need to be screened to
obtain a respondent sample of 1,350. The screener is expected to take
30 seconds, for a total screener burden of 17 hours. The 1,350
respondents will then be asked to respond to a series of questions
about the advertisement. We estimate the response burden for the
consumer part of the survey to be 15 minutes, for a burden of 337.5
hours. The estimated total burden for this data collection effort is
354.5 hours. The respondent burden chart is listed below:
Estimated Annual Reporting Burden
----------------------------------------------------------------------------------------------------------------
Annual frequency Total annual Hours per
No. of respondents per response responses response Total hours
----------------------------------------------------------------------------------------------------------------
2,025 (screener) 1 2,025 .008 17
----------------------------------------------------------------------------------------------------------------
1,350 (questionnaire) 1 1,350 .25 337.5
----------------------------------------------------------------------------------------------------------------
Total .................... 3,375 ................. 354.5
----------------------------------------------------------------------------------------------------------------
Footnote: there are no capital costs or operating and maintenance costs associated with this data collection.
Dated: January 30, 2006.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. E6-1521 Filed 2-3-06; 8:45 am]
BILLING CODE 4160-01-S