Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Experimental Evaluation of the Impact of Distraction on Consumer Understanding of Risk and Benefit Information in Direct-to-Consumer Prescription Drug Broadcast Advertisements, 79887-79889 [E8-31057]
Download as PDF
Federal Register / Vol. 73, No. 250 / Tuesday, December 30, 2008 / Notices
Government-wide, electronic docket
management system. Electronic
comments or submissions will be
accepted by FDA only through FDMS at
https://www.regulations.gov.
Dated: December 22, 2008.
Jeffrey Shuren,
Associate Commissioner for Policy and
Planning.
[FR Doc. E8–31058 Filed 12–29–08; 8:45 am]
BILLING CODE 4160–01–S
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2007–N–0451] (formerly
Docket No. 2007N–0321)
Agency Information Collection
Activities; Submission for Office of
Management and Budget Review;
Comment Request; Experimental
Evaluation of the Impact of Distraction
on Consumer Understanding of Risk
and Benefit Information in Direct-toConsumer Prescription Drug
Broadcast Advertisements
AGENCY:
Food and Drug Administration,
HHS.
pwalker on PROD1PC71 with NOTICES
ACTION:
Notice.
SUMMARY: The Food and Drug
Administration (FDA) is announcing
that a proposed collection of
information has been submitted to the
Office of Management and Budget
(OMB) for review and clearance under
the Paperwork Reduction Act of 1995.
Due to an administrative error, this
document is being republished.
DATES: Fax written comments on the
collection of information by January 29,
2009.
ADDRESSES: To ensure that comments on
the information collection are received,
OMB recommends that written
comments be faxed to the Office of
Information and Regulatory Affairs,
OMB, Attn: FDA Desk Officer, FAX:
202–395–6974, or e-mailed to
oira_submission@omb.eop.gov. All
comments should be identified with the
OMB control number 0910–NEW and
title ‘‘Experimental Evaluation of the
Impact of Distraction on Consumer
Understanding of Risk and Benefit
Information in Direct-to-Consumer
Prescription Drug Broadcast
Advertisements.’’ Also include the FDA
docket number found in brackets in the
heading of this document.
FOR FURTHER INFORMATION CONTACT:
Elizabeth Berbakos, Office of
Information Management (HFA–710),
Food and Drug Administration, 5600
VerDate Aug<31>2005
22:55 Dec 29, 2008
Jkt 217001
Fishers Lane, Rockville, MD 20857,
301–796–3792.
SUPPLEMENTARY INFORMATION: In
compliance with 44 U.S.C. 3507, FDA
has submitted the following proposed
collection of information to OMB for
review and clearance.
Experimental Evaluation of the Impact
of Distraction on Consumer
Understanding of Risk and Benefit
Information in Direct-to-Consumer
Prescription Drug Broadcast
Advertisements
Section 1701(a)(4) of the Public
Health Service Act (42 U.S.C.
300u(a)(4)) authorizes FDA to conduct
research relating to health information.
Section 903(b)(2)(c) of the Federal Food,
Drug, and Cosmetic Act (the act) (21
U.S.C. 393(b)(2)(c)) authorizes FDA to
conduct research relating to drugs and
other FDA regulated products in
carrying out the provisions of the act.
FDA regulations require that
advertisements that make claims about
a prescription drug include a ‘‘fair
balance’’ of information about the
benefits and risks of advertised
products, in terms of both content and
presentation. Ads can present
information in ways that can optimize
or skew the relative balance of risks and
benefits. Both healthcare providers and
consumers have expressed concerns to
FDA about the effectiveness of its
regulation of manufacturers’ Direct-toConsumer (DTC) prescription drug
advertising, especially as it relates to
assuring balanced communication of
risks compared with benefits.
One characteristic of DTC television
broadcast ads is the use of compelling
visuals. Many assert that the visuals
present during the product risk
presentation are virtually always
positive in tone and often depict
product benefits. A consistently raised
question is whether advertising visuals
of benefits interferes with consumers’
understanding and processing of the
risk information in the ad’s audio or
text.
The manner in which required risk
information is presented in DTC ads has
been recently addressed in the Food and
Drug Administration Amendments Act
of 2007 (FDAAA). Section 901(3) of
FDAAA states that the major statement
in DTC broadcast ads ‘‘shall be
presented in a clear, conspicuous and
neutral manner.’’ Further, the Secretary
of Health and Human Services ‘‘shall
establish standards for determining
whether the major statement is
presented in such a manner.’’ FDAAA
does not define how the objective of
‘‘clear, conspicuous, and neutral’’ is to
be achieved.
PO 00000
Frm 00099
Fmt 4703
Sfmt 4703
79887
The purpose of the proposed study is,
in part, to determine whether the use of
competing, compelling visual
information about potential drug
benefits interferes with viewers’
processing and comprehension of risk
information about drugs in DTC
advertising or with their cognitive
representations of the drugs. Positive
visual images could influence the
processing of risk-related information
and the final representation of the
advertised drug in multiple ways. First,
compelling visuals could simply
distract consumers from carefully
considering and encoding the risk
information. To the extent that
compelling visuals cause them to attend
to or to process risk information less,
participants exposed to risk information
with simultaneous compelling positive
visuals should recall fewer risks (and
perhaps fewer benefits) than do
participants exposed to the risk
information without the positive
visuals. Second, compelling visuals may
affect the way consumers think about
the brand, specifically their attitudes
toward the advertised brand. An
attitude is simply an association
between an object and a degree of
positivity or negativity. Thus, the
impact of varying visual displays during
the presentation of audio risks may be
manifested in varying attitudes toward
the brand. This is important because
brand attitudes may be an important
determinant of future behavior toward
the brand. In contexts where product
information is complex, initial
impressions based on more subtle
processes may have as significant an
impact on behavioral tendencies as
impressions based upon more
‘‘cognitively-effortful’’ factual
information. Because visual cues are
typically easier to process than verbal
information, initial attitudes for this
group are likely to be greatly influenced
by these cues. Under many
circumstances, people rely much less on
facts that they know, such as the
number of risks associated with, for
example, ibuprofen, and much more on
general feelings they have, such as
strong positivity toward a brand, such as
the Advil brand of ibuprofen.
Compelling visuals during the audio
risk presentation of DTC broadcast
advertisements have the potential to
lead a consumer to form a positive
opinion of a drug for no other reason
than that it is presented in the same
context as positive images.
Another purpose of the present study
is to examine the role of textual
elements in the processing of risk
information. Sponsors often place
E:\FR\FM\30DEN1.SGM
30DEN1
pwalker on PROD1PC71 with NOTICES
79888
Federal Register / Vol. 73, No. 250 / Tuesday, December 30, 2008 / Notices
superimposed text (‘‘supers’’) onto the
screen to clarify spoken information or
to provide extra information that is not
included in the audio. For example,
information that fulfills certain
requirements (such as adequate
provision statements, for example ‘‘See
our ad in * * *’’) and limits claims of
product use may appear. Providing
verbatim text repetition of the risks
required to be in the audio portion in
broadcast ads may facilitate processing
the risks, but only if viewers pay
attention to the text. Viewers’ attention
may be affected by both the prominence
of the textual information and the
combined effects of text prominence
and different visual information. The
proposed study examines these
associations.
A final purpose of this study is to
provide FDA with information on
defining the presentation of the major
statement as ‘‘clear, conspicuous, and
neutral’’ as required by FDAAA. We
have limited data about how consumers
perceive risk and benefit information in
DTC broadcast ads as a function of
exposure to different content and
presentations. Therefore, we do not
fully understand the influence of visual
and textual factors on the conveyance of
a balanced or ‘‘neutral’’ picture of the
product.
This study will investigate the impact
of visual distraction and the interplay of
different sensory modalities (oral,
visual) used to present risk and benefit
information during a television
prescription drug advertisement. Data
from this study will provide useful
information for FDA as it considers
whether it is appropriate to develop
guidance to help improve how
broadcast ads present a prescription
drug’s risks and benefits. This study
will also provide preliminary data on
how FDA might interpret the ‘‘clear,
conspicuous, and neutral’’ standard.
The data should help us plan whether
additional research is needed to develop
the standards called for in FDAAA.
Overview: To investigate the overall
and interactive role of visual images and
text presentations during the audio
presentation of risk information in
television DTC ads, we will create a
variety of ads for a new (fictitious)
brand of high blood pressure
medication. The ads will vary only in
the type of information shown on screen
during the presentation of required risk
information (the ‘‘major statement’’). We
will conduct pretesting to determine
whether participants will view one
version of the test ad two times or if the
test ad will be viewed in the context of
other ads (‘‘clutter reel’’). Respondents
will answer questions about the test ad,
VerDate Aug<31>2005
22:55 Dec 29, 2008
Jkt 217001
including information about product
risks and benefits, whether they intend
to ask the doctor about the product,
basic comprehension of the risk and
benefit information, and their general
attitudes toward the product. This
experimental design will allow for
comparisons between conditions in a
controlled presentation where only the
visual information varies.
Design: The study includes two
primary designs that, taken together,
investigate three different variables.
A one-way, five condition design will
examine the impact of degree of
consistency between visuals presented
during orally presented (audio) risk
information. The visuals will be either
very consistent, somewhat consistent,
neutral, somewhat inconsistent, or very
inconsistent with the audio risk
information. The consistent conditions
will visually reinforce the product risks
by presenting the words of the risks on
the screen as they are being spoken. The
inconsistent conditions will reinforce
the product’s benefits by presenting
visuals that suggest blood pressure
being decreased from high to normal
levels. The degree or magnitude of
consistency will be manipulated by
including fewer pieces of information,
interspersed with images of the
fictitious drug logo. A control or
‘‘neutral’’ condition will consist of
showing the brand logo during the
entire audio risk presentation.
The second design will be a two-way
factorial design combining each level of
one independent variable with each
level of a second independent variable.
The first variable consists of three levels
of visual ‘‘tone’’—neutral, mildly
positive, and highly positive. The
second variable consists of three levels
of prominence of ‘‘supers’’—level one,
level two, and no super (control).
Because the control cell in each of the
2 designs will overlap (neutral, no
supers), both designs together will
amount to a total of 13 separate ‘‘cells’’
and corresponding versions of
advertisements for the fictitious brand.
In a separate sub-experiment, five
selected cells taken from across the two
designs will assess implicit attitudes
using the Attitude Misattribution
Procedure (AMP). The questions asked
of the participants in the AMP
conditions will be reduced in number to
account for the additional time needed
to administer the AMP.
Eligible participants for the study
(n=2,400, following pretesting) will be
recruited from Synovate Inc.’s online
Internet panel. They will be 40 years of
age or older to increase the likelihood of
including members of the population
most likely to have high blood pressure.
PO 00000
Frm 00100
Fmt 4703
Sfmt 4703
At least 30 percent of the recruited
sample within each of the designs will
have equal to or less than a high school
education. The composition of
participants in each format condition
will be balanced with respect to gender
(50% female, +/- 10%). Panel members
who meet age and education
requirements will not be screened
further for disease condition.
Dependent Measures: The primary
dependent variables are recall and
comprehension of risk and benefit
information. We will also investigate
behavioral intention and attitudes
toward the fictitious brand. In a separate
sub-experiment using only five cells
throughout both designs, we will use
the AMP, in addition to some explicit
measures, to collect implicit attitude
measures that should not be affected by
social desirability biases.
In the Federal Register of August 22,
2007 (72 FR 47051), FDA published a
60-day notice requesting public
comment on the information collection
provisions. Thirty commenters
responded. In total, this amounted to
approximately 29 distinct comments
that specifically referenced the study. Of
these, 12 were not PRA related. As a
result of the comments that were PRArelated, FDA made extensive
modifications to the study’s
methodology and design. As reflected in
these modifications, we agreed to do the
following: Change from a mall-intercept
to an Internet administered procedure,
limit use of the AMP to a subexperiment consisting of only five of the
experimental conditions, add questions
addressing the advertised (fictitious)
drug’s benefits, and make certain
changes to the wording of the questions.
Changing the administration procedure
also allows us to double our sample size
and test more conditions. In response to
comments received both from the
commenters and from our peer
reviewers, we also decided to conduct
significantly more pretesting than
originally planned, to address the
suggestion that the test ad should be
embedded in a clutter reel of other ads
and to test the validity of the stimulus
manipulations (the mocked up
advertisements). We disagreed,
primarily because of time and
complexity constraints, with
suggestions to do the following: (1) Add
more independent variables, (2) recruit
a different set of participants, (3) change
the use of Chinese characters in the
(now more limited) AMP-measured
conditions, (4) add certain additional
dependent measures, (5) increase or
decrease the number of behavioral
intention questions (both were
requested), (6) control for baseline
E:\FR\FM\30DEN1.SGM
30DEN1
79889
Federal Register / Vol. 73, No. 250 / Tuesday, December 30, 2008 / Notices
attitudes (because this is not needed in
an experimental design and we are
using a fictitious drug for the stimulus
materials), or (7) get industry approval
and public comment on the mocked up
ads.
FDA estimates the burden of this
collection of information as follows:
TABLE 1.—ESTIMATED ANNUAL REPORTING BURDEN1
No. of
Respondents
21 CFR Section
Annual Frequency
per Response
Total Annual
Responses
Hours per
Response
Total Hours
21 U.S.C. 393(b)(2)(c) Screener,
pretesting
1,600
1
1,600
.03
48
21 U.S.C. 393(b)(2)(c) Questionnaire, pretesting
800
1
800
.16
128
21 U.S.C. 393(b)(2)(c) Screener,
study
4,800
1
4,800
.03
144
21 U.S.C. 393(b)(2)(c) Questionnaire, study
2,400
1
2,400
.25
600
Total
1 There
920
are no capital costs or operating and maintenance costs associated with this collection of information.
Dated: December 18, 2008.
Jeffrey Shuren,
Associate Commissioner for Policy and
Planning.
[FR Doc. E8–31057 Filed 12–29–08; 8:45 am]
BILLING CODE 4160–01–S
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
National Institutes of Health
Proposed Collection; Comment
Request; Women’s Health Initiative
Observational Study
SUMMARY: In compliance with the
requirement of Section 3506(c)(2)(A) of
the Paperwork Reduction Act of 1995,
for opportunity for public comment on
proposed data collection projects, the
National Heart, Lung, and Blood
Institute (NHLBI), the National
Institutes of Health (NIH) will publish
periodic summaries of proposed
projects to be submitted to the Office of
Management and Budget (OMB) for
review and approval.
Proposed Collection: Title: The
Women’s Health Initiative (WHI)
Observational Study. Type of
Information Collection Request:
Revision OMB #0925–0414. Need and
Use of Information Collection: This
study will be used by the NIH to
evaluate risk factors for chronic disease
among older women by developing and
following a large cohort of
postmenopausal women and relating
subsequent disease development to
baseline assessments of historical,
physical, psychosocial, and physiologic
characteristics. In addition, the
observational study will complement
the clinical trial (which has received
clinical exemption) and provide
additional information on the common
causes of frailty, disability and death for
postmenopausal women, namely,
coronary heart disease, breast and
colorectal cancer, and osteoporotic
fractures. Continuation of follow-up for
ascertainment of medical history update
forms will provide essential data for
outcomes assessment for this population
of aging women. Frequency of Response:
Annually. Affected Public: Individuals
or households and health care
providers. Type of Respondents:
Individuals or households; health care
providers. The annual reporting burden
is as follows:
ESTIMATE OF ANNUAL HOUR BURDEN
Number of
respondents
Type of response
Average
hours per
response
Frequency
of response
Observational Study Participants ................................................................
Next of Kin 1 .................................................................................................
Health Care Providers 1 ...............................................................................
63,230
1163
9
1.1
1
1
.338
.083
.083
Total ......................................................................................................
64,402
..........................
........................
Annual hour
burden
23,509
97
.77
23,607
1 Annual
pwalker on PROD1PC71 with NOTICES
burden is placed on health care providers and respondent relatives/informants through requests for information which will help in the
compilation of the number and nature of new fatal and nonfatal events.
The annualized cost to respondents is
estimated at $377,725, assuming
respondents time at the rate of $16 per
hour and physician time at the rate of
$50 per hour. There are no Capital Costs
to report. There are no Operating or
Maintenance Costs to report.
Request for Comments: Written
comments and/or suggestions from the
VerDate Aug<31>2005
22:55 Dec 29, 2008
Jkt 217001
public and affected agencies are invited
on one or more of the following points:
(1) Whether the proposed collection of
information is necessary for the proper
performance of the function of the
agency, including whether the
information will have practical utility;
(2) The accuracy of the agency’s
estimate of the burden of the proposed
PO 00000
Frm 00101
Fmt 4703
Sfmt 4703
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 those who
are to respond, including the use of
appropriate automated, electronic,
E:\FR\FM\30DEN1.SGM
30DEN1
Agencies
[Federal Register Volume 73, Number 250 (Tuesday, December 30, 2008)]
[Notices]
[Pages 79887-79889]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-31057]
-----------------------------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA-2007-N-0451] (formerly Docket No. 2007N-0321)
Agency Information Collection Activities; Submission for Office
of Management and Budget Review; Comment Request; Experimental
Evaluation of the Impact of Distraction on Consumer Understanding of
Risk and Benefit Information in Direct-to-Consumer Prescription Drug
Broadcast Advertisements
AGENCY: Food and Drug Administration, HHS.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Food and Drug Administration (FDA) is announcing that a
proposed collection of information has been submitted to the Office of
Management and Budget (OMB) for review and clearance under the
Paperwork Reduction Act of 1995. Due to an administrative error, this
document is being republished.
DATES: Fax written comments on the collection of information by January
29, 2009.
ADDRESSES: To ensure that comments on the information collection are
received, OMB recommends that written comments be faxed to the Office
of Information and Regulatory Affairs, OMB, Attn: FDA Desk Officer,
FAX: 202-395-6974, or e-mailed to oira_submission@omb.eop.gov. All
comments should be identified with the OMB control number 0910-NEW and
title ``Experimental Evaluation of the Impact of Distraction on
Consumer Understanding of Risk and Benefit Information in Direct-to-
Consumer Prescription Drug Broadcast Advertisements.'' Also include the
FDA docket number found in brackets in the heading of this document.
FOR FURTHER INFORMATION CONTACT: Elizabeth Berbakos, Office of
Information Management (HFA-710), Food and Drug Administration, 5600
Fishers Lane, Rockville, MD 20857, 301-796-3792.
SUPPLEMENTARY INFORMATION: In compliance with 44 U.S.C. 3507, FDA has
submitted the following proposed collection of information to OMB for
review and clearance.
Experimental Evaluation of the Impact of Distraction on Consumer
Understanding of Risk and Benefit Information in Direct-to-Consumer
Prescription Drug Broadcast Advertisements
Section 1701(a)(4) of the Public Health Service Act (42 U.S.C.
300u(a)(4)) authorizes FDA to conduct research relating to health
information. Section 903(b)(2)(c) of the Federal Food, Drug, and
Cosmetic Act (the act) (21 U.S.C. 393(b)(2)(c)) authorizes FDA to
conduct research relating to drugs and other FDA regulated products in
carrying out the provisions of the act.
FDA regulations require that advertisements that make claims about
a prescription drug include a ``fair balance'' of information about the
benefits and risks of advertised products, in terms of both content and
presentation. Ads can present information in ways that can optimize or
skew the relative balance of risks and benefits. Both healthcare
providers and consumers have expressed concerns to FDA about the
effectiveness of its regulation of manufacturers' Direct-to-Consumer
(DTC) prescription drug advertising, especially as it relates to
assuring balanced communication of risks compared with benefits.
One characteristic of DTC television broadcast ads is the use of
compelling visuals. Many assert that the visuals present during the
product risk presentation are virtually always positive in tone and
often depict product benefits. A consistently raised question is
whether advertising visuals of benefits interferes with consumers'
understanding and processing of the risk information in the ad's audio
or text.
The manner in which required risk information is presented in DTC
ads has been recently addressed in the Food and Drug Administration
Amendments Act of 2007 (FDAAA). Section 901(3) of FDAAA states that the
major statement in DTC broadcast ads ``shall be presented in a clear,
conspicuous and neutral manner.'' Further, the Secretary of Health and
Human Services ``shall establish standards for determining whether the
major statement is presented in such a manner.'' FDAAA does not define
how the objective of ``clear, conspicuous, and neutral'' is to be
achieved.
The purpose of the proposed study is, in part, to determine whether
the use of competing, compelling visual information about potential
drug benefits interferes with viewers' processing and comprehension of
risk information about drugs in DTC advertising or with their cognitive
representations of the drugs. Positive visual images could influence
the processing of risk-related information and the final representation
of the advertised drug in multiple ways. First, compelling visuals
could simply distract consumers from carefully considering and encoding
the risk information. To the extent that compelling visuals cause them
to attend to or to process risk information less, participants exposed
to risk information with simultaneous compelling positive visuals
should recall fewer risks (and perhaps fewer benefits) than do
participants exposed to the risk information without the positive
visuals. Second, compelling visuals may affect the way consumers think
about the brand, specifically their attitudes toward the advertised
brand. An attitude is simply an association between an object and a
degree of positivity or negativity. Thus, the impact of varying visual
displays during the presentation of audio risks may be manifested in
varying attitudes toward the brand. This is important because brand
attitudes may be an important determinant of future behavior toward the
brand. In contexts where product information is complex, initial
impressions based on more subtle processes may have as significant an
impact on behavioral tendencies as impressions based upon more
``cognitively-effortful'' factual information. Because visual cues are
typically easier to process than verbal information, initial attitudes
for this group are likely to be greatly influenced by these cues. Under
many circumstances, people rely much less on facts that they know, such
as the number of risks associated with, for example, ibuprofen, and
much more on general feelings they have, such as strong positivity
toward a brand, such as the Advil brand of ibuprofen. Compelling
visuals during the audio risk presentation of DTC broadcast
advertisements have the potential to lead a consumer to form a positive
opinion of a drug for no other reason than that it is presented in the
same context as positive images.
Another purpose of the present study is to examine the role of
textual elements in the processing of risk information. Sponsors often
place
[[Page 79888]]
superimposed text (``supers'') onto the screen to clarify spoken
information or to provide extra information that is not included in the
audio. For example, information that fulfills certain requirements
(such as adequate provision statements, for example ``See our ad in * *
*'') and limits claims of product use may appear. Providing verbatim
text repetition of the risks required to be in the audio portion in
broadcast ads may facilitate processing the risks, but only if viewers
pay attention to the text. Viewers' attention may be affected by both
the prominence of the textual information and the combined effects of
text prominence and different visual information. The proposed study
examines these associations.
A final purpose of this study is to provide FDA with information on
defining the presentation of the major statement as ``clear,
conspicuous, and neutral'' as required by FDAAA. We have limited data
about how consumers perceive risk and benefit information in DTC
broadcast ads as a function of exposure to different content and
presentations. Therefore, we do not fully understand the influence of
visual and textual factors on the conveyance of a balanced or
``neutral'' picture of the product.
This study will investigate the impact of visual distraction and
the interplay of different sensory modalities (oral, visual) used to
present risk and benefit information during a television prescription
drug advertisement. Data from this study will provide useful
information for FDA as it considers whether it is appropriate to
develop guidance to help improve how broadcast ads present a
prescription drug's risks and benefits. This study will also provide
preliminary data on how FDA might interpret the ``clear, conspicuous,
and neutral'' standard. The data should help us plan whether additional
research is needed to develop the standards called for in FDAAA.
Overview: To investigate the overall and interactive role of visual
images and text presentations during the audio presentation of risk
information in television DTC ads, we will create a variety of ads for
a new (fictitious) brand of high blood pressure medication. The ads
will vary only in the type of information shown on screen during the
presentation of required risk information (the ``major statement''). We
will conduct pretesting to determine whether participants will view one
version of the test ad two times or if the test ad will be viewed in
the context of other ads (``clutter reel''). Respondents will answer
questions about the test ad, including information about product risks
and benefits, whether they intend to ask the doctor about the product,
basic comprehension of the risk and benefit information, and their
general attitudes toward the product. This experimental design will
allow for comparisons between conditions in a controlled presentation
where only the visual information varies.
Design: The study includes two primary designs that, taken
together, investigate three different variables.
A one-way, five condition design will examine the impact of degree
of consistency between visuals presented during orally presented
(audio) risk information. The visuals will be either very consistent,
somewhat consistent, neutral, somewhat inconsistent, or very
inconsistent with the audio risk information. The consistent conditions
will visually reinforce the product risks by presenting the words of
the risks on the screen as they are being spoken. The inconsistent
conditions will reinforce the product's benefits by presenting visuals
that suggest blood pressure being decreased from high to normal levels.
The degree or magnitude of consistency will be manipulated by including
fewer pieces of information, interspersed with images of the fictitious
drug logo. A control or ``neutral'' condition will consist of showing
the brand logo during the entire audio risk presentation.
The second design will be a two-way factorial design combining each
level of one independent variable with each level of a second
independent variable. The first variable consists of three levels of
visual ``tone''--neutral, mildly positive, and highly positive. The
second variable consists of three levels of prominence of ``supers''--
level one, level two, and no super (control).
Because the control cell in each of the 2 designs will overlap
(neutral, no supers), both designs together will amount to a total of
13 separate ``cells'' and corresponding versions of advertisements for
the fictitious brand.
In a separate sub-experiment, five selected cells taken from across
the two designs will assess implicit attitudes using the Attitude
Misattribution Procedure (AMP). The questions asked of the participants
in the AMP conditions will be reduced in number to account for the
additional time needed to administer the AMP.
Eligible participants for the study (n=2,400, following pretesting)
will be recruited from Synovate Inc.'s online Internet panel. They will
be 40 years of age or older to increase the likelihood of including
members of the population most likely to have high blood pressure. At
least 30 percent of the recruited sample within each of the designs
will have equal to or less than a high school education. The
composition of participants in each format condition will be balanced
with respect to gender (50% female, +[sol]- 10%). Panel members who
meet age and education requirements will not be screened further for
disease condition.
Dependent Measures: The primary dependent variables are recall and
comprehension of risk and benefit information. We will also investigate
behavioral intention and attitudes toward the fictitious brand. In a
separate sub-experiment using only five cells throughout both designs,
we will use the AMP, in addition to some explicit measures, to collect
implicit attitude measures that should not be affected by social
desirability biases.
In the Federal Register of August 22, 2007 (72 FR 47051), FDA
published a 60-day notice requesting public comment on the information
collection provisions. Thirty commenters responded. In total, this
amounted to approximately 29 distinct comments that specifically
referenced the study. Of these, 12 were not PRA related. As a result of
the comments that were PRA-related, FDA made extensive modifications to
the study's methodology and design. As reflected in these
modifications, we agreed to do the following: Change from a mall-
intercept to an Internet administered procedure, limit use of the AMP
to a sub-experiment consisting of only five of the experimental
conditions, add questions addressing the advertised (fictitious) drug's
benefits, and make certain changes to the wording of the questions.
Changing the administration procedure also allows us to double our
sample size and test more conditions. In response to comments received
both from the commenters and from our peer reviewers, we also decided
to conduct significantly more pretesting than originally planned, to
address the suggestion that the test ad should be embedded in a clutter
reel of other ads and to test the validity of the stimulus
manipulations (the mocked up advertisements). We disagreed, primarily
because of time and complexity constraints, with suggestions to do the
following: (1) Add more independent variables, (2) recruit a different
set of participants, (3) change the use of Chinese characters in the
(now more limited) AMP-measured conditions, (4) add certain additional
dependent measures, (5) increase or decrease the number of behavioral
intention questions (both were requested), (6) control for baseline
[[Page 79889]]
attitudes (because this is not needed in an experimental design and we
are using a fictitious drug for the stimulus materials), or (7) get
industry approval and public comment on the mocked up ads.
FDA estimates the burden of this collection of information as
follows:
Table 1.--Estimated Annual Reporting Burden\1\
----------------------------------------------------------------------------------------------------------------
No. of Annual Frequency Total Annual Hours per
21 CFR Section Respondents per Response Responses Response Total Hours
----------------------------------------------------------------------------------------------------------------
21 U.S.C. 1,600 1 1,600 .03 48
393(b)(2)(c)
Screener,
pretesting
----------------------------------------------------------------------------------------------------------------
21 U.S.C. 800 1 800 .16 128
393(b)(2)(c)
Questionnaire
, pretesting
----------------------------------------------------------------------------------------------------------------
21 U.S.C. 4,800 1 4,800 .03 144
393(b)(2)(c)
Screener,
study
----------------------------------------------------------------------------------------------------------------
21 U.S.C. 2,400 1 2,400 .25 600
393(b)(2)(c)
Questionnaire
, study
----------------------------------------------------------------------------------------------------------------
Total 920
----------------------------------------------------------------------------------------------------------------
\1\ There are no capital costs or operating and maintenance costs associated with this collection of
information.
Dated: December 18, 2008.
Jeffrey Shuren,
Associate Commissioner for Policy and Planning.
[FR Doc. E8-31057 Filed 12-29-08; 8:45 am]
BILLING CODE 4160-01-S