Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Market Claims in Direct-to-Consumer Prescription Drug Print Ads, 26807-26811 [2016-10396]
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Federal Register / Vol. 81, No. 86 / Wednesday, May 4, 2016 / Notices
In
compliance with 44 U.S.C. 3507, FDA
has submitted the following proposed
collection of information to OMB for
review and clearance.
SUPPLEMENTARY INFORMATION:
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2015–N–2406]
Agency Information Collection
Activities; Submission for Office of
Management and Budget Review;
Comment Request; Market Claims in
Direct-to-Consumer Prescription Drug
Print Ads
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice.
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.
DATES: Fax written comments on the
collection of information by June 3,
2016.
SUMMARY:
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:
202–395–7285, or emailed to oira_
submission@omb.eop.gov. All
comments should be identified with the
OMB control number 0910—NEW and
title, ‘‘Market Claims in Direct-toConsumer Prescription Drug Print Ads.’’
Also include the FDA docket number
found in brackets in the heading of this
document.
FOR FURTHER INFORMATION CONTACT: FDA
PRA Staff, Office of Operations, Food
and Drug Administration, 8455
Colesville Rd., COLE–14526, Silver
Spring, MD 20993–002, PRAStaff@
fda.hhs.gov.
ADDRESSES:
Market Claims in Direct-to-Consumer
Prescription Drug Print Ads—OMB
Control Number 0910—NEW
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 1003(d)(2)(C) of the Federal
Food, Drug, and Cosmetic Act (the
FD&C Act) (21 U.S.C. 393(d)(2)(C))
authorizes FDA to conduct research
relating to drugs and other FDA
regulated products in carrying out the
provisions of the FD&C Act.
The marketing literature divides
product attributes (‘‘cues’’) into intrinsic
and extrinsic. Intrinsic cues are physical
characteristics of the product (e.g., size,
shape), whereas extrinsic cues are
product-related but not part of the
product (e.g., price and brand name)
(Refs. 1 and 2). Research has found that
both intrinsic and extrinsic cues can
influence perceptions of product quality
(Ref. 3). Consumers may rely on product
cues in the absence of explicit quality
information. The objective quality of
prescription drugs is not easily obtained
from promotional claims in direct-toconsumer (DTC) ads; thus consumers
may rely upon extrinsic cues to inform
their decisions. Market claims such as
‘‘#1 Prescribed’’ and ‘‘New’’ may act as
extrinsic cues about the product’s
quality, independent of the product’s
intrinsic characteristics. Prior research
has found that market leadership claims
can affect consumer beliefs about
product efficacy, as well as their beliefs
about doctors’ judgments about product
efficacy (Ref. 4). One limitation of these
prior studies is the lack of quantitative
information about product efficacy in
the information provided to
respondents. Research indicates that
providing consumers with efficacy
information generally improves
understanding and facilitates
decisionmaking (Refs. 5 and 6). Efficacy
information may moderate the effect of
the extrinsic cue by providing insight
into characteristics that would
otherwise be unknown. Other research
has shown that consumers are able to
use information about efficacy to inform
judgments about the product (Refs. 6
and 7).
The Office of Prescription Drug
Promotion (OPDP) plans to investigate,
through empirical research, the impact
of market claims on prescription drug
product perceptions with and without
quantitative information about product
efficacy. This will be investigated in
DTC print advertising for prescription
drugs.
I. Design Overview and Procedure
The design consists of two parts: A
main study and a followup study. We
will conduct two sequential pretest
waves prior to the main study and one
pretest prior to the followup study. The
purpose of the pretests are to (1) ensure
the stimuli are understandable and
viewable, (2) identify and address any
challenges to embedding the stimuli
within the online survey, and (3) ensure
the study questions are appropriate and
meet the study’s goals.
Participants in the main study will be
randomly assigned to view one of nine
versions of an ad, as depicted in table
1. The two variables of interest are type
of market claim (#1 Prescribed, New)
and type of efficacy information (High,
Low, or None). Efficacy information will
be operationalized in the form of
realistic quantitative information (for
example, ‘‘46 percent of patients felt
their nerve pain reduced by at least half,
compared to baseline’’).
TABLE 1—MAIN STUDY DESIGN
Type of market claim
#1 Prescribed
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Efficacy Level Information:
High ......................................................................................................................................
Low .......................................................................................................................................
None (control) .......................................................................................................................
In the followup study, participants
(n = 216) will complete a 15-minute
paired choice experiment. Participants
will be asked to choose between two
hypothetical drugs based on print ads,
one of which includes a market claim
from the Main Study (#1 Prescribed or
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New). The ads also include different
efficacy information (for example, ‘‘46
percent of patients felt their nerve pain
reduced by at least half, compared to
baseline’’ versus ‘‘51 percent of patients
felt their nerve pain reduced by at least
half, compared to baseline’’). Figure 1
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New
None (control)
........................
A
D
G
........................
B
E
H
........................
C
F
I
depicts an example choice. Participants
are asked to indicate which drug they
would prefer. They are given 48 such
choice sets, which vary in efficacy
information and the presence of the
market claim.
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II. Procedure
Pretests: Each participant will be
randomly assigned to view a print ad for
a fictitious prescription drug indicated
to treat diabetic neuropathy and will be
asked to complete an online survey
assessing their benefit/risk perceptions,
intentions, and attitudes toward the
drug. Based on the pretest findings, we
will revise and remove poorly
performing survey items prior to fullscale testing.
Main study: Each participant will be
randomly assigned to view a print ad for
a fictitious prescription drug for diabetic
neuropathy and will be asked to
complete an online survey assessing
their benefit/risk perceptions,
intentions, and attitudes toward the
drug.
Followup study: Each participant will
be asked to view a series of pairs of
print ads for a product that treats
diabetic neuropathy. One ad will
contain a market claim. Both ads will
contain quantitative efficacy
information that varies along a
continuum of effectiveness in a series of
48 trials. In each comparison,
participants will be asked to choose one
of the two drugs.
In the Federal Register of July 20,
2015 (80 FR 42823), FDA published a
60-day notice requesting public
comment on the proposed collection of
information. Six submissions were
received; three from biopharmaceutical
companies (AbbVie, Eli Lilly, Merck),
two that were anonymous, and one from
Danny Weiss, PharmD. The comments
from the two anonymous submitters and
Dr. Weiss requested the United States
ban DTC advertising for
pharmaceuticals. This is outside the
scope of this project. We summarize and
respond to the other comments as
follows.
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(Comment 1) From AbbVie:
Respondents may view ‘‘benefits’’ and
‘‘risks’’ more generally versus ‘‘side
effects’’ as a specific inquiry. For
example, ‘‘side effects’’ could be
interpreted as adverse effects or adverse
events, and as such, elicit a much more
specific response than ‘‘risks’’ which
could be seen more broadly. We suggest
that ‘‘side effects’’ be eliminated from
question 4 to keep questions 3 and 4 as
both general in nature.
(Response) We are interested in recall
of both risks and side effects, and so we
inquire about both. Inquiring about risks
only may artificially reduce the quantity
of recall. Moreover, we counterbalance
the presentation of questions 3 and 4 in
efforts to account for any influence of
question ordering. It would be feasible
to instead inquire about risks and side
effects in separate questions; however,
in our experience, we find that
consumers tend to think about risks and
side effects together, which makes sense
given the typical presentation of risks
and side effects in direct-to-consumer
promotional materials.
(Comment 2) From AbbVie: The
answers to questions 7 through 12 may
be biased by attitudes toward
advertising in general and may go well
beyond the pharmaceutical ad they are
shown.
(Response) By asking these questions,
we hope to detect any differences in
perceived effectiveness and risk
between those exposed to different
experimental conditions. For example,
those exposed to an ad with a #1
Prescribed market claim may perceive
the product to be more effective than
those in the control condition. We
acknowledge participants may bring
their own opinions about advertising to
the study. However, these opinions tend
to be evenly distributed across
experimental conditions based on
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random assignment procedures. Thus,
any differences result from the
experimental manipulations.
(Comment 3) From AbbVie: We
acknowledge we have not seen the test
ad; but, we wish to point out that
questions 13 and 17 rely on the ad
presenting numeric efficacy and safety
information that can be interpreted by
respondents.
(Response) Prior research has shown
that consumers can reach numeric
judgments about efficacy and risk
despite no numeric information being
presented (Ref. 5). As described in our
study design (see table 1), we are not
manipulating quantitative safety
information and not all test ads contain
quantitative efficacy information. We
have worked with an expert reviewer in
OPDP to produce efficacy claims that
are realistic for this drug product class.
(Comment 4) From AbbVie: Question
18 relies on the ad presenting
information about the seriousness of one
or more ‘‘side effects’’ that the
respondent could rank. We do not
usually see print ads that present details
about the extent of the seriousness of
one or more side effects. In the absence
of this presentation, how are
respondents to answer this question?
(Response) We find that consumers
are generally able to differentiate
between the seriousness of various risks
and side effects, and also that they can
make judgments about the overall (gist)
seriousness of the risks and side effects.
We ask this question with the intention
to detect whether or not exposure to
market claims and efficacy information
impacts risk perceptions.
(Comment 5) From AbbVie: The
answers to questions 21 to 26 may
reflect a patient’s perception of their
doctor rather than the ad. Therefore, the
answers may not reflect what was
communicated in the ad but rather
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reflect the patient-doctor relationship
(e.g., patient perception of their doctor).
(Response) We are endeavoring to
replicate the results of Mitra et al. (Ref.
4), who found that market leadership
claims affected consumer beliefs about
doctor’s judgments.
(Comment 6) From AbbVie: In the
table headers for questions 27 and 28,
please change ‘‘claim’’ to ‘‘statement’’ so
that it matches the text in the question.
(Response) We will make this change.
(Comment 7) From AbbVie: It is
beneficial to rotate the order of response
choices in questions 27 and 28 as is
done in prior questions. Some of the
features a–h are broad (b. pictures and
images) while some are specific (e.
percentages). It would be better to
compare the very general features in a
question and group the very specific
features into another question to
compare like features.
(Response) We will make this change.
(Comment 8) From AbbVie: For
questions 35 to 38, rather than rank
from Strongly Disagree to Strongly
Agree, which are absolutes, it would be
better to rank by frequency from Never
to Always; this moves the response to
how often patients perceive this and
away from absolutes.
(Response) We acknowledge that it is
difficult to rank agree/disagree on all
drugs. However, a scale range of
Always-Never is unipolar; we can’t
assess whether respondents think the
opposite, e.g., that New drugs tend to be
more risky or that the #1 Prescribed
drug is more risky. Our intention is to
use these items as a moderator when
examining the impact of the
experimental manipulations (i.e.,
market claims, efficacy claims) on
benefit and risk perceptions, intentions
to take the product, and other outcomes.
We believe the most relevant scale for
this analysis is the current Strongly
Disagree to Strongly Agree scale.
Although it would be interesting to
assess participant responding using both
scales, doing so may not add significant
value relative to the additional burden
it would pose for participants.
(Comment 9) From AbbVie: We
suggest that all the features of question
43a to h be stated in the affirmative/
positive. For example, question 43h
should be worded as ‘‘the drug has few
side effects’’ to be consistent with
features of question 43a to g that are
positively stated.
(Response) The proposed item, ‘‘the
drug has few side effects,’’ assesses a
different outcome than our current
question, ‘‘the drug has serious side
effects.’’ We have also added items
assessing ‘‘drug cost and/or copay’’ and
‘‘doctor’s recommendation.’’ For
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consistency, we will change the
wording so that all features are neutral
(for instance: The drug’s side effects,
opinions of people I know, how often
the drug is prescribed).
(Comment 10) From Lilly: Given the
proposed FDA research questions, Lilly
believes the design is appropriate and
the sample size will allow for breakouts
by each cell. In advertising A/B tests, in
which this is similar to, all aspects of
the stimulus not being tested are held
the same in order to reduce bias and
isolate the feature being tested. We
strongly recommend that this guideline
is followed in this study.
(Response) We intend to hold all
features other than the manipulations
constant in the stimuli.
(Comment 11) From Lilly: One
research objective for the main study
suggests that the study will measure
perceptions of the doctors’ acceptance
of the drug by respondents. Since
respondents will only be seeing a print
ad and not interacting with a doctor, we
believe the research setting will be too
artificial to gain meaningful insights
into this topic. We recommend
removing the section (questions 21 to
26).
(Response) Please see response to
Comment 5 from AbbVie.
(Comment 12) From Lilly: The details
of the followup study are less clear than
the main study. What are the techniques
and what are the dependent measures
on which the respondent will be asked
to decide?
(Response) The followup study
assesses the relative weighting of a
market claim and efficacy in
decisionmaking. Participants are asked
to choose a drug out of two options that
vary in (1) the presence of a market
claim and (2) efficacy. We will examine
product preference as a function of
efficacy using logistic regression. The
difference in efficacy between the two
drugs on each choice set will be a
continuous predictor variable and drug
choice will be a binary outcome
variable. Critically, we will examine
whether, and to what extent, the
efficacy-choice relationship varies as a
function of an added market claim; thus,
market claim presence will be an
interaction term. The experiment uses a
discrete choice approach common in
psychology and economics (Ref. 8).
(Comment 13) From Lilly: We suggest
FDA stratify the sample for both studies
across demographic variables to ensure
it is representative of the U.S. diabetic
population.
(Response) We are applying
demographic quotas to achieve a
representative sample.
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(Comment 14) From Lilly: The
questionnaire employs a number of
different Likert scales that differ on the
number of scale values and definition of
values. Lilly suggests using a standard
five-point scale with a mid-point and
definitions for each value for all scalar
questions.
(Response) We have changed the
Likert scales to be internally consistent.
(Comment 15) From Lilly: For
questions 9 and 16, by asking the
respondents to perceive overall quality
of the drug, the survey risks introducing
perceptions outside of experimental
control into the study. Overall quality is
a very broad topic and might be
dependent on the graphics, wording,
and personal biases that are outside of
the market claims and efficacy levels
being tested. We suggest removing these
questions, or changing the question to
‘‘overall efficacy.’’
(Response) By asking these questions,
we hope to detect any differences in
perceived quality between those
exposed to different experimental
conditions. For example, those exposed
to an ad with a #1 Prescribed market
claim may perceive the product to be of
higher quality than those in the control
condition. By keeping all ad elements
beyond the experimental manipulations
(market claims, efficacy claims)
constant, we can ensure that significant
differences between conditions are a
result of the manipulations rather than
any extraneous factors. Random
assignment to conditions should also
distribute any random variance equally
across all cells.
(Comment 16) From Lilly: We
recommend removing questions 13 and
17 as they have the potential to be
misinterpreted or simply difficult for
the respondent to answer if the stimulus
is not communicating prevalence of the
drug’s side effects or benefits using
precise numbers.
(Response) Please see response to
Comment 3 from AbbVie.
(Comment 17) From Lilly: For
questions 27 and 28, we recommend
slightly changing the wordings for the
possible answer choices to ‘‘Yes/No,
claim is/is not mentioned as a benefit in
the ad’’ for question 27, and ‘‘Yes/No,
claim is/is not mentioned as a side
effect or risk in the ad’’ for question 28.
(Response) We agree that more
specific wording would be helpful and
have revised the answer choices to read
‘‘Yes, statement is mentioned in the ad’’
and ‘‘No, statement is not mentioned in
the ad.’’
(Comment 18) From Lilly:
Recommend removing question 31 as
the question is an inverse of question 30
to avoid confounding data.
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(Response) We have removed
question 31 (skepticism).
(Comment 19) From Lilly: The
instructions for the questions 35
through 38 section seem to have an
omitted word. We recommend revising
to ‘‘how much do you agree or disagree
with the following statements?’’
(Response) Thank you for pointing
this out. We will correct this.
(Comment 20) From Lilly: We agree
with placement of demographic
questions (questions 39–44) at the end
but recommend reevaluating them and
consider removing them so as to avoid
lack of response due to respondent
fatigue.
(Response) The comment about
respondent fatigue is well taken.
However, we are adhering to good
questionnaire design in putting our
most important dependent measures
first and are willing to accept the
potential tradeoff in missing
demographic data.
(Comment 21) From Lilly: We suggest
providing a more complete list of
choices for question 43 and placing this
question earlier in the study.
(Response) We appreciate this
suggestion and have added questions
about cost.
(Comment 22) From Merck: Merck
supports the importance of
communicating information that can be
understood by consumers so that they
can make better decisions about
prescription drugs. We believe that FDA
should focus their efforts and research
first on improving the health literacy of
approved patient labeling and then on
DTC print advertising. In addition, FDA
should consider exploring the inclusion
of benefit information in patient
labeling, which may help improve
consumer understanding and
comprehension of patient labeling.
(Response) We share the goal of
improving communications about
prescription drugs. There are efforts
underway within FDA examining ways
to improve patient labeling (Ref. 9).
Although this comment is outside the
scope of this project, we will share this
information internally.
(Comment 23) From Merck: Merck
believes the current study design limits
the practical utility of the information
collected. The study proposes
presenting efficacy information in the
form of simple quantitative information.
Prior OPDP research acknowledged the
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limitations of studying simple
quantitative information. For many
prescription drugs, clinical trial
outcomes are often more complicated
than simple frequencies, which limit the
applicability of this research. Numeracy
challenges are common in people with
inadequate health literacy. Numeracy
challenges are not well represented in
online research, and hence the proposed
methodology may not detect a lack of
comprehension.
(Response) We are pleased Merck has
read FDA’s prior research in the area of
communicating quantitative
information. As this is the first study
examining the impact of quantitative
efficacy information on the perception
of market share claims, we felt it was
better to start with relatively
straightforward, though not simplistic,
quantitative efficacy information. We
have worked with an expert reviewer in
OPDP to product efficacy claims that are
realistic for this drug product class. The
efficacy claim communicates both the
level of expected benefit and the
likelihood of experiencing that benefit.
We encourage additional research on
this topic utilizing increasingly complex
quantitative information.
We have included a measure of
numeracy in our questionnaire. We
acknowledge that online panels may
underrepresent individuals with
extremely low health literacy. Thus, any
differences we find as a function of
numeracy in our sample may be
magnified in the general population.
(Comment 24) From Merck: Merck
recommends a mixed-method approach
to reach limited-literacy respondents.
The phone or Web approach allows for
a broad, diverse geographic sample.
Respondents with low health literacy
are not typically represented in these
databases, and may need to be recruited
in less traditional places, such as
literacy centers, senior centers, and
health clinics. Additionally, if a desktop
computer is required, this may
inadvertently eliminate respondents
from low socioeconomic status, who are
less likely to have a desktop computer
and more likely to have internet only on
their mobile device.
(Response) We acknowledge that
internet administration is not perfect
and have chosen this method to
maximize our budget. We will permit
the survey to be taken on a variety of
devices. We are excluding phones
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because the stimuli cannot be fully
viewed on a very small screen.
(Comment 25) From Merck: For the
followup study, we recommend
reducing the number of trials for
respondents across health literacy
levels, as respondent fatigue can occur,
resulting in reduced focus and
unreliably responses. Refining the
methodology to present fewer choices to
each respondent, and assuring the
clarity of the information presented,
would help to enhance comprehension.
(Response) We agree that minimizing
respondent burden is a priority. We
estimate that the 48 trials and
instructions would require less than 8
minutes, on average. Pretest data may
reveal that the experiment can be
shortened without loss to validity, in
which case we will reduce the number
of trials.
(Comment 26) From Merck: Questions
6, 32, and 50 include percentages.
According to Health Literacy Missouri,
natural frequencies (1 out of 10) may be
more useful than percentages. Research
suggests that less literate readers may
interpret numbers as more risky when
in frequency form (1 out of 10) versus
percentage form (10 percent).
(Response) We have worked with an
expert reviewer in OPDP to product
efficacy claims that are realistic for this
drug product class.
(Comment 27) From Merck: We
suggest adding the following screener
question to increase the odds of
recruiting limited-literacy respondents:
‘‘How confident are you in filling out
medical forms by yourself?’’
(Response) We acknowledge that
internet panels underrepresent
individuals with very low literacy.
Thus, it is important to acknowledge
that our findings may not apply to very
low literacy individuals. It would be
prohibitively expensive for us to screen
for literacy up front in order to establish
quotas. We will measure health literacy
and included it in analyses.
The first two pretests and main study
are expected to last no more than 30
minutes. The third pretest and followup
study are expected to last no more than
15 minutes. This will be a one-time
(rather than annual) collection of
information. FDA estimates the burden
of this collection of information as
follows:
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26811
TABLE 2—ESTIMATED BURDEN 1
Number of
respondents
Activity
Number of
responses per
respondent
Total
respondents
Average burden per
response
Total hours
Sample Outgo (Pretests and Main Survey) ................
Screener Completes ....................................................
Eligible .........................................................................
Completes, Pretest 1 ...................................................
Completes, Pretest 2 ...................................................
Completes, Main Study ...............................................
Completes, Pretest 3 ...................................................
Completes, Followup Study .........................................
16,384
1,638
1,556
252
252
495
108
216
........................
1
........................
1
1
1
1
1
........................
1,638
........................
252
252
495
108
216
................................
0.03 (2 minutes) .....
................................
0.5 (30 minutes) .....
0.5 (30 minutes) .....
0.5 (30 minutes) .....
0.25 (15 minutes) ..
0.25 (15 minutes) ...
........................
49.1
........................
126
126
247.5
27
54
Total ......................................................................
........................
........................
........................
................................
629.6
1 There
are no capital costs or operating and maintenance costs associated with this collection of information.
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III. References
The following references are on
display in the Division of Dockets
Management (see ADDRESSES) and are
available for viewing by interested
persons between 9 a.m. and 4 p.m.,
Monday through Friday; they are also
available electronically at https://
www.regulations.gov. FDA has verified
the Web site addresses, as of the date
this document publishes in the Federal
Register, but Web sites are subject to
change over time.
1. Lee, M. and Y-C. Lou, ‘‘Consumer Reliance
on Intrinsic and Extrinsic Cues in
Product Evaluations: A Conjoint
Approach,’’ Journal of Applied Business
Research, 12(1):21–29, 2011.
2. Teas, R.K. and S. Agarwal, ‘‘The Effects of
Extrinsic Product Cues on Consumers’
Perceptions of Quality, Sacrifice, and
Value,’’ Journal of the Academy of
Marketing Science, 28(2):278–290, 2000.
3. Rao, A.R. and K.B. Monroe, ‘‘The Effect of
Price, Brand Name, and Store Name on
Buyers’ Perceptions of Product Quality:
An Integrative Review,’’ Journal of
Marketing Research, 26(3):351–357,
1989.
4. Mitra, A., J.L. Swasy, and K.J. Aikin, ‘‘How
Do Consumers Interpret Market
Leadership Claims in Direct-toConsumer Advertising of Prescription
Drugs?’’ Advances in Consumer
Research, 33:381–387, 2006.
5. O’Donoghue, A.C., H.W. Sullivan, K.J.
Aikin, et al., ‘‘Presenting Efficacy
Information in Direct-to-Consumer
Prescription Drug Advertisements,’’
Patient Education and Counseling,
95(2):271–280, 2014.
6. Schwartz, L.M., S. Woloshin, and H.G.
Welch, ‘‘Using a Drug Facts Box to
Communicate Drug Benefits and Harms:
Two Randomized Trials,’’ Annals of
Internal Medicine, 150(8):516–527, 2009.
7. Sullivan, H.W., A.C. O’Donoghue, and K.J.
Aikin, ‘‘Presenting Quantitative
Information About Placebo Rates to
Patients,’’ JAMA Internal Medicine,
173(2):2006–2007, 2013.
8. Train, K.E., Discrete Choice Methods With
Simulation, Cambridge University Press,
2009.
9. Boudewyns, V., A.C. O’Donoghue, B.
VerDate Sep<11>2014
18:44 May 03, 2016
Jkt 238001
Kelly, et al., ‘‘Influence of Patient
Medication Information Format on
Comprehension and Application of
Medication Information: A Randomized,
Controlled Experiment,’’ Patient
Education and Counseling, 98(12):1592–
1599, 2015.
Dated: April 28, 2016.
Leslie Kux,
Associate Commissioner for Policy.
[FR Doc. 2016–10396 Filed 5–3–16; 8:45 am]
BILLING CODE 4164–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Meeting of the National Preparedness
and Response Science Board
Department of Health and
Human Services, Office of the Secretary.
ACTION: Notice.
AGENCY:
As stipulated by the Federal
Advisory Committee Act, the
Department of Health and Human
Services (HHS) is hereby giving notice
that the National Preparedness and
Response Science Board (NPRSB) will
be holding a public teleconference.
DATES: The NPRSB will hold a public
meeting on May 26, 2016, from 1:00
p.m. to 2:00 p.m. EST. The agenda is
subject to change as priorities dictate.
ADDRESSES: Individuals who wish to
participate should send an email to
NPRSB@HHS.GOV with ‘‘NPRSB
Registration’’ in the subject line. The
meeting will occur by teleconference.
To attend via teleconference and for
further instructions, please visit the
NPRSB Web site at WWW.PHE.GOV/
NPRSB.
SUMMARY:
FOR FURTHER INFORMATION CONTACT:
Please submit an inquiry via the NPRSB
Contact Form located at www.phe.gov/
NBSBComments.
Pursuant
to section 319M of the Public Health
SUPPLEMENTARY INFORMATION:
PO 00000
Frm 00039
Fmt 4703
Sfmt 4703
Service Act (42 U.S.C. 247d–7f) and
section 222 of the Public Health Service
Act (42 U.S.C. 217a), HHS established
the NPRSB. The Board shall provide
expert advice and guidance to the
Secretary on scientific, technical, and
other matters of special interest to HHS
regarding current and future chemical,
biological, nuclear, and radiological
agents, whether naturally occurring,
accidental, or deliberate. The NPRSB
may also provide advice and guidance
to the Secretary and/or the Assistant
Secretary for Preparedness and
Response (ASPR) on other matters
related to public health emergency
preparedness and response.
Background: This public meeting via
teleconference will be dedicated to the
NPRSB’s deliberation and vote on the
task letter received from the ASPR.
Subsequent agenda topics will be added
as priorities dictate. Any additional
agenda topics will be available on the
NPRSB May 26, 2016, meeting Web
page, available at WWW.PHE.GOV/
NPRSB.
Availability of Materials: The meeting
agenda and materials will be posted
prior to the meeting on the May 26th
meeting Web page at WWW.PHE.GOV/
NPRSB.
Procedures for Providing Public Input:
Members of the public are invited to
attend by teleconference via a toll-free
call-in phone number which is available
on the NPRSB Web site at
WWW.PHE.GOV/NPRSB. All members
of the public are encouraged to provide
written comment to the NPRSB. All
written comments must be received
prior to May 26, 2016, and should be
sent by email to NPRSB@HHS.GOV with
‘‘NPRSB Public Comment’’ as the
subject line. Public comments received
by close of business one week prior to
each teleconference will be distributed
to the NPRSB in advance.
E:\FR\FM\04MYN1.SGM
04MYN1
Agencies
[Federal Register Volume 81, Number 86 (Wednesday, May 4, 2016)]
[Notices]
[Pages 26807-26811]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-10396]
[[Page 26807]]
-----------------------------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA-2015-N-2406]
Agency Information Collection Activities; Submission for Office
of Management and Budget Review; Comment Request; Market Claims in
Direct-to-Consumer Prescription Drug Print Ads
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.
DATES: Fax written comments on the collection of information by June 3,
2016.
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: 202-395-7285, or emailed to oira_submission@omb.eop.gov. All
comments should be identified with the OMB control number 0910--NEW and
title, ``Market Claims in Direct-to-Consumer Prescription Drug Print
Ads.'' Also include the FDA docket number found in brackets in the
heading of this document.
FOR FURTHER INFORMATION CONTACT: FDA PRA Staff, Office of Operations,
Food and Drug Administration, 8455 Colesville Rd., COLE-14526, Silver
Spring, MD 20993-002, PRAStaff@fda.hhs.gov.
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.
Market Claims in Direct-to-Consumer Prescription Drug Print Ads--OMB
Control Number 0910--NEW
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 1003(d)(2)(C) of the Federal Food, Drug, and
Cosmetic Act (the FD&C Act) (21 U.S.C. 393(d)(2)(C)) authorizes FDA to
conduct research relating to drugs and other FDA regulated products in
carrying out the provisions of the FD&C Act.
The marketing literature divides product attributes (``cues'') into
intrinsic and extrinsic. Intrinsic cues are physical characteristics of
the product (e.g., size, shape), whereas extrinsic cues are product-
related but not part of the product (e.g., price and brand name) (Refs.
1 and 2). Research has found that both intrinsic and extrinsic cues can
influence perceptions of product quality (Ref. 3). Consumers may rely
on product cues in the absence of explicit quality information. The
objective quality of prescription drugs is not easily obtained from
promotional claims in direct-to-consumer (DTC) ads; thus consumers may
rely upon extrinsic cues to inform their decisions. Market claims such
as ``#1 Prescribed'' and ``New'' may act as extrinsic cues about the
product's quality, independent of the product's intrinsic
characteristics. Prior research has found that market leadership claims
can affect consumer beliefs about product efficacy, as well as their
beliefs about doctors' judgments about product efficacy (Ref. 4). One
limitation of these prior studies is the lack of quantitative
information about product efficacy in the information provided to
respondents. Research indicates that providing consumers with efficacy
information generally improves understanding and facilitates
decisionmaking (Refs. 5 and 6). Efficacy information may moderate the
effect of the extrinsic cue by providing insight into characteristics
that would otherwise be unknown. Other research has shown that
consumers are able to use information about efficacy to inform
judgments about the product (Refs. 6 and 7).
The Office of Prescription Drug Promotion (OPDP) plans to
investigate, through empirical research, the impact of market claims on
prescription drug product perceptions with and without quantitative
information about product efficacy. This will be investigated in DTC
print advertising for prescription drugs.
I. Design Overview and Procedure
The design consists of two parts: A main study and a followup
study. We will conduct two sequential pretest waves prior to the main
study and one pretest prior to the followup study. The purpose of the
pretests are to (1) ensure the stimuli are understandable and viewable,
(2) identify and address any challenges to embedding the stimuli within
the online survey, and (3) ensure the study questions are appropriate
and meet the study's goals.
Participants in the main study will be randomly assigned to view
one of nine versions of an ad, as depicted in table 1. The two
variables of interest are type of market claim (#1 Prescribed, New) and
type of efficacy information (High, Low, or None). Efficacy information
will be operationalized in the form of realistic quantitative
information (for example, ``46 percent of patients felt their nerve
pain reduced by at least half, compared to baseline'').
Table 1--Main Study Design
----------------------------------------------------------------------------------------------------------------
Type of market claim
--------------------------------------------------
#1 Prescribed New None (control)
----------------------------------------------------------------------------------------------------------------
Efficacy Level Information: ............... ............... ...............
High..................................................... A B C
Low...................................................... D E F
None (control)........................................... G H I
----------------------------------------------------------------------------------------------------------------
In the followup study, participants (n = 216) will complete a 15-
minute paired choice experiment. Participants will be asked to choose
between two hypothetical drugs based on print ads, one of which
includes a market claim from the Main Study (#1 Prescribed or New). The
ads also include different efficacy information (for example, ``46
percent of patients felt their nerve pain reduced by at least half,
compared to baseline'' versus ``51 percent of patients felt their nerve
pain reduced by at least half, compared to baseline''). Figure 1
depicts an example choice. Participants are asked to indicate which
drug they would prefer. They are given 48 such choice sets, which vary
in efficacy information and the presence of the market claim.
[[Page 26808]]
[GRAPHIC] [TIFF OMITTED] TN04MY16.000
II. Procedure
Pretests: Each participant will be randomly assigned to view a
print ad for a fictitious prescription drug indicated to treat diabetic
neuropathy and will be asked to complete an online survey assessing
their benefit/risk perceptions, intentions, and attitudes toward the
drug. Based on the pretest findings, we will revise and remove poorly
performing survey items prior to full-scale testing.
Main study: Each participant will be randomly assigned to view a
print ad for a fictitious prescription drug for diabetic neuropathy and
will be asked to complete an online survey assessing their benefit/risk
perceptions, intentions, and attitudes toward the drug.
Followup study: Each participant will be asked to view a series of
pairs of print ads for a product that treats diabetic neuropathy. One
ad will contain a market claim. Both ads will contain quantitative
efficacy information that varies along a continuum of effectiveness in
a series of 48 trials. In each comparison, participants will be asked
to choose one of the two drugs.
In the Federal Register of July 20, 2015 (80 FR 42823), FDA
published a 60-day notice requesting public comment on the proposed
collection of information. Six submissions were received; three from
biopharmaceutical companies (AbbVie, Eli Lilly, Merck), two that were
anonymous, and one from Danny Weiss, PharmD. The comments from the two
anonymous submitters and Dr. Weiss requested the United States ban DTC
advertising for pharmaceuticals. This is outside the scope of this
project. We summarize and respond to the other comments as follows.
(Comment 1) From AbbVie: Respondents may view ``benefits'' and
``risks'' more generally versus ``side effects'' as a specific inquiry.
For example, ``side effects'' could be interpreted as adverse effects
or adverse events, and as such, elicit a much more specific response
than ``risks'' which could be seen more broadly. We suggest that ``side
effects'' be eliminated from question 4 to keep questions 3 and 4 as
both general in nature.
(Response) We are interested in recall of both risks and side
effects, and so we inquire about both. Inquiring about risks only may
artificially reduce the quantity of recall. Moreover, we counterbalance
the presentation of questions 3 and 4 in efforts to account for any
influence of question ordering. It would be feasible to instead inquire
about risks and side effects in separate questions; however, in our
experience, we find that consumers tend to think about risks and side
effects together, which makes sense given the typical presentation of
risks and side effects in direct-to-consumer promotional materials.
(Comment 2) From AbbVie: The answers to questions 7 through 12 may
be biased by attitudes toward advertising in general and may go well
beyond the pharmaceutical ad they are shown.
(Response) By asking these questions, we hope to detect any
differences in perceived effectiveness and risk between those exposed
to different experimental conditions. For example, those exposed to an
ad with a #1 Prescribed market claim may perceive the product to be
more effective than those in the control condition. We acknowledge
participants may bring their own opinions about advertising to the
study. However, these opinions tend to be evenly distributed across
experimental conditions based on random assignment procedures. Thus,
any differences result from the experimental manipulations.
(Comment 3) From AbbVie: We acknowledge we have not seen the test
ad; but, we wish to point out that questions 13 and 17 rely on the ad
presenting numeric efficacy and safety information that can be
interpreted by respondents.
(Response) Prior research has shown that consumers can reach
numeric judgments about efficacy and risk despite no numeric
information being presented (Ref. 5). As described in our study design
(see table 1), we are not manipulating quantitative safety information
and not all test ads contain quantitative efficacy information. We have
worked with an expert reviewer in OPDP to produce efficacy claims that
are realistic for this drug product class.
(Comment 4) From AbbVie: Question 18 relies on the ad presenting
information about the seriousness of one or more ``side effects'' that
the respondent could rank. We do not usually see print ads that present
details about the extent of the seriousness of one or more side
effects. In the absence of this presentation, how are respondents to
answer this question?
(Response) We find that consumers are generally able to
differentiate between the seriousness of various risks and side
effects, and also that they can make judgments about the overall (gist)
seriousness of the risks and side effects. We ask this question with
the intention to detect whether or not exposure to market claims and
efficacy information impacts risk perceptions.
(Comment 5) From AbbVie: The answers to questions 21 to 26 may
reflect a patient's perception of their doctor rather than the ad.
Therefore, the answers may not reflect what was communicated in the ad
but rather
[[Page 26809]]
reflect the patient-doctor relationship (e.g., patient perception of
their doctor).
(Response) We are endeavoring to replicate the results of Mitra et
al. (Ref. 4), who found that market leadership claims affected consumer
beliefs about doctor's judgments.
(Comment 6) From AbbVie: In the table headers for questions 27 and
28, please change ``claim'' to ``statement'' so that it matches the
text in the question.
(Response) We will make this change.
(Comment 7) From AbbVie: It is beneficial to rotate the order of
response choices in questions 27 and 28 as is done in prior questions.
Some of the features a-h are broad (b. pictures and images) while some
are specific (e. percentages). It would be better to compare the very
general features in a question and group the very specific features
into another question to compare like features.
(Response) We will make this change.
(Comment 8) From AbbVie: For questions 35 to 38, rather than rank
from Strongly Disagree to Strongly Agree, which are absolutes, it would
be better to rank by frequency from Never to Always; this moves the
response to how often patients perceive this and away from absolutes.
(Response) We acknowledge that it is difficult to rank agree/
disagree on all drugs. However, a scale range of Always-Never is
unipolar; we can't assess whether respondents think the opposite, e.g.,
that New drugs tend to be more risky or that the #1 Prescribed drug is
more risky. Our intention is to use these items as a moderator when
examining the impact of the experimental manipulations (i.e., market
claims, efficacy claims) on benefit and risk perceptions, intentions to
take the product, and other outcomes. We believe the most relevant
scale for this analysis is the current Strongly Disagree to Strongly
Agree scale. Although it would be interesting to assess participant
responding using both scales, doing so may not add significant value
relative to the additional burden it would pose for participants.
(Comment 9) From AbbVie: We suggest that all the features of
question 43a to h be stated in the affirmative/positive. For example,
question 43h should be worded as ``the drug has few side effects'' to
be consistent with features of question 43a to g that are positively
stated.
(Response) The proposed item, ``the drug has few side effects,''
assesses a different outcome than our current question, ``the drug has
serious side effects.'' We have also added items assessing ``drug cost
and/or copay'' and ``doctor's recommendation.'' For consistency, we
will change the wording so that all features are neutral (for instance:
The drug's side effects, opinions of people I know, how often the drug
is prescribed).
(Comment 10) From Lilly: Given the proposed FDA research questions,
Lilly believes the design is appropriate and the sample size will allow
for breakouts by each cell. In advertising A/B tests, in which this is
similar to, all aspects of the stimulus not being tested are held the
same in order to reduce bias and isolate the feature being tested. We
strongly recommend that this guideline is followed in this study.
(Response) We intend to hold all features other than the
manipulations constant in the stimuli.
(Comment 11) From Lilly: One research objective for the main study
suggests that the study will measure perceptions of the doctors'
acceptance of the drug by respondents. Since respondents will only be
seeing a print ad and not interacting with a doctor, we believe the
research setting will be too artificial to gain meaningful insights
into this topic. We recommend removing the section (questions 21 to
26).
(Response) Please see response to Comment 5 from AbbVie.
(Comment 12) From Lilly: The details of the followup study are less
clear than the main study. What are the techniques and what are the
dependent measures on which the respondent will be asked to decide?
(Response) The followup study assesses the relative weighting of a
market claim and efficacy in decisionmaking. Participants are asked to
choose a drug out of two options that vary in (1) the presence of a
market claim and (2) efficacy. We will examine product preference as a
function of efficacy using logistic regression. The difference in
efficacy between the two drugs on each choice set will be a continuous
predictor variable and drug choice will be a binary outcome variable.
Critically, we will examine whether, and to what extent, the efficacy-
choice relationship varies as a function of an added market claim;
thus, market claim presence will be an interaction term. The experiment
uses a discrete choice approach common in psychology and economics
(Ref. 8).
(Comment 13) From Lilly: We suggest FDA stratify the sample for
both studies across demographic variables to ensure it is
representative of the U.S. diabetic population.
(Response) We are applying demographic quotas to achieve a
representative sample.
(Comment 14) From Lilly: The questionnaire employs a number of
different Likert scales that differ on the number of scale values and
definition of values. Lilly suggests using a standard five-point scale
with a mid-point and definitions for each value for all scalar
questions.
(Response) We have changed the Likert scales to be internally
consistent.
(Comment 15) From Lilly: For questions 9 and 16, by asking the
respondents to perceive overall quality of the drug, the survey risks
introducing perceptions outside of experimental control into the study.
Overall quality is a very broad topic and might be dependent on the
graphics, wording, and personal biases that are outside of the market
claims and efficacy levels being tested. We suggest removing these
questions, or changing the question to ``overall efficacy.''
(Response) By asking these questions, we hope to detect any
differences in perceived quality between those exposed to different
experimental conditions. For example, those exposed to an ad with a #1
Prescribed market claim may perceive the product to be of higher
quality than those in the control condition. By keeping all ad elements
beyond the experimental manipulations (market claims, efficacy claims)
constant, we can ensure that significant differences between conditions
are a result of the manipulations rather than any extraneous factors.
Random assignment to conditions should also distribute any random
variance equally across all cells.
(Comment 16) From Lilly: We recommend removing questions 13 and 17
as they have the potential to be misinterpreted or simply difficult for
the respondent to answer if the stimulus is not communicating
prevalence of the drug's side effects or benefits using precise
numbers.
(Response) Please see response to Comment 3 from AbbVie.
(Comment 17) From Lilly: For questions 27 and 28, we recommend
slightly changing the wordings for the possible answer choices to
``Yes/No, claim is/is not mentioned as a benefit in the ad'' for
question 27, and ``Yes/No, claim is/is not mentioned as a side effect
or risk in the ad'' for question 28.
(Response) We agree that more specific wording would be helpful and
have revised the answer choices to read ``Yes, statement is mentioned
in the ad'' and ``No, statement is not mentioned in the ad.''
(Comment 18) From Lilly: Recommend removing question 31 as the
question is an inverse of question 30 to avoid confounding data.
[[Page 26810]]
(Response) We have removed question 31 (skepticism).
(Comment 19) From Lilly: The instructions for the questions 35
through 38 section seem to have an omitted word. We recommend revising
to ``how much do you agree or disagree with the following statements?''
(Response) Thank you for pointing this out. We will correct this.
(Comment 20) From Lilly: We agree with placement of demographic
questions (questions 39-44) at the end but recommend reevaluating them
and consider removing them so as to avoid lack of response due to
respondent fatigue.
(Response) The comment about respondent fatigue is well taken.
However, we are adhering to good questionnaire design in putting our
most important dependent measures first and are willing to accept the
potential tradeoff in missing demographic data.
(Comment 21) From Lilly: We suggest providing a more complete list
of choices for question 43 and placing this question earlier in the
study.
(Response) We appreciate this suggestion and have added questions
about cost.
(Comment 22) From Merck: Merck supports the importance of
communicating information that can be understood by consumers so that
they can make better decisions about prescription drugs. We believe
that FDA should focus their efforts and research first on improving the
health literacy of approved patient labeling and then on DTC print
advertising. In addition, FDA should consider exploring the inclusion
of benefit information in patient labeling, which may help improve
consumer understanding and comprehension of patient labeling.
(Response) We share the goal of improving communications about
prescription drugs. There are efforts underway within FDA examining
ways to improve patient labeling (Ref. 9). Although this comment is
outside the scope of this project, we will share this information
internally.
(Comment 23) From Merck: Merck believes the current study design
limits the practical utility of the information collected. The study
proposes presenting efficacy information in the form of simple
quantitative information. Prior OPDP research acknowledged the
limitations of studying simple quantitative information. For many
prescription drugs, clinical trial outcomes are often more complicated
than simple frequencies, which limit the applicability of this
research. Numeracy challenges are common in people with inadequate
health literacy. Numeracy challenges are not well represented in online
research, and hence the proposed methodology may not detect a lack of
comprehension.
(Response) We are pleased Merck has read FDA's prior research in
the area of communicating quantitative information. As this is the
first study examining the impact of quantitative efficacy information
on the perception of market share claims, we felt it was better to
start with relatively straightforward, though not simplistic,
quantitative efficacy information. We have worked with an expert
reviewer in OPDP to product efficacy claims that are realistic for this
drug product class. The efficacy claim communicates both the level of
expected benefit and the likelihood of experiencing that benefit. We
encourage additional research on this topic utilizing increasingly
complex quantitative information.
We have included a measure of numeracy in our questionnaire. We
acknowledge that online panels may underrepresent individuals with
extremely low health literacy. Thus, any differences we find as a
function of numeracy in our sample may be magnified in the general
population.
(Comment 24) From Merck: Merck recommends a mixed-method approach
to reach limited-literacy respondents. The phone or Web approach allows
for a broad, diverse geographic sample. Respondents with low health
literacy are not typically represented in these databases, and may need
to be recruited in less traditional places, such as literacy centers,
senior centers, and health clinics. Additionally, if a desktop computer
is required, this may inadvertently eliminate respondents from low
socioeconomic status, who are less likely to have a desktop computer
and more likely to have internet only on their mobile device.
(Response) We acknowledge that internet administration is not
perfect and have chosen this method to maximize our budget. We will
permit the survey to be taken on a variety of devices. We are excluding
phones because the stimuli cannot be fully viewed on a very small
screen.
(Comment 25) From Merck: For the followup study, we recommend
reducing the number of trials for respondents across health literacy
levels, as respondent fatigue can occur, resulting in reduced focus and
unreliably responses. Refining the methodology to present fewer choices
to each respondent, and assuring the clarity of the information
presented, would help to enhance comprehension.
(Response) We agree that minimizing respondent burden is a
priority. We estimate that the 48 trials and instructions would require
less than 8 minutes, on average. Pretest data may reveal that the
experiment can be shortened without loss to validity, in which case we
will reduce the number of trials.
(Comment 26) From Merck: Questions 6, 32, and 50 include
percentages. According to Health Literacy Missouri, natural frequencies
(1 out of 10) may be more useful than percentages. Research suggests
that less literate readers may interpret numbers as more risky when in
frequency form (1 out of 10) versus percentage form (10 percent).
(Response) We have worked with an expert reviewer in OPDP to
product efficacy claims that are realistic for this drug product class.
(Comment 27) From Merck: We suggest adding the following screener
question to increase the odds of recruiting limited-literacy
respondents: ``How confident are you in filling out medical forms by
yourself?''
(Response) We acknowledge that internet panels underrepresent
individuals with very low literacy. Thus, it is important to
acknowledge that our findings may not apply to very low literacy
individuals. It would be prohibitively expensive for us to screen for
literacy up front in order to establish quotas. We will measure health
literacy and included it in analyses.
The first two pretests and main study are expected to last no more
than 30 minutes. The third pretest and followup study are expected to
last no more than 15 minutes. This will be a one-time (rather than
annual) collection of information. FDA estimates the burden of this
collection of information as follows:
[[Page 26811]]
Table 2--Estimated Burden \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Activity Number of responses per Total Average burden per response Total hours
respondents respondent respondents
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sample Outgo (Pretests and Main Survey)...... 16,384 .............. .............. ......................................... ..............
Screener Completes........................... 1,638 1 1,638 0.03 (2 minutes)......................... 49.1
Eligible..................................... 1,556 .............. .............. ......................................... ..............
Completes, Pretest 1......................... 252 1 252 0.5 (30 minutes)......................... 126
Completes, Pretest 2......................... 252 1 252 0.5 (30 minutes)......................... 126
Completes, Main Study........................ 495 1 495 0.5 (30 minutes)......................... 247.5
Completes, Pretest 3......................... 108 1 108 0.25 (15 minutes)........................ 27
Completes, Followup Study.................... 216 1 216 0.25 (15 minutes)........................ 54
----------------------------------------------------------------------------------------------------------
Total.................................... .............. .............. .............. ......................................... 629.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ There are no capital costs or operating and maintenance costs associated with this collection of information.
III. References
The following references are on display in the Division of Dockets
Management (see ADDRESSES) and are available for viewing by interested
persons between 9 a.m. and 4 p.m., Monday through Friday; they are also
available electronically at https://www.regulations.gov. FDA has
verified the Web site addresses, as of the date this document publishes
in the Federal Register, but Web sites are subject to change over time.
1. Lee, M. and Y-C. Lou, ``Consumer Reliance on Intrinsic and
Extrinsic Cues in Product Evaluations: A Conjoint Approach,''
Journal of Applied Business Research, 12(1):21-29, 2011.
2. Teas, R.K. and S. Agarwal, ``The Effects of Extrinsic Product
Cues on Consumers' Perceptions of Quality, Sacrifice, and Value,''
Journal of the Academy of Marketing Science, 28(2):278-290, 2000.
3. Rao, A.R. and K.B. Monroe, ``The Effect of Price, Brand Name, and
Store Name on Buyers' Perceptions of Product Quality: An Integrative
Review,'' Journal of Marketing Research, 26(3):351-357, 1989.
4. Mitra, A., J.L. Swasy, and K.J. Aikin, ``How Do Consumers
Interpret Market Leadership Claims in Direct-to-Consumer Advertising
of Prescription Drugs?'' Advances in Consumer Research, 33:381-387,
2006.
5. O'Donoghue, A.C., H.W. Sullivan, K.J. Aikin, et al., ``Presenting
Efficacy Information in Direct-to-Consumer Prescription Drug
Advertisements,'' Patient Education and Counseling, 95(2):271-280,
2014.
6. Schwartz, L.M., S. Woloshin, and H.G. Welch, ``Using a Drug Facts
Box to Communicate Drug Benefits and Harms: Two Randomized Trials,''
Annals of Internal Medicine, 150(8):516-527, 2009.
7. Sullivan, H.W., A.C. O'Donoghue, and K.J. Aikin, ``Presenting
Quantitative Information About Placebo Rates to Patients,'' JAMA
Internal Medicine, 173(2):2006-2007, 2013.
8. Train, K.E., Discrete Choice Methods With Simulation, Cambridge
University Press, 2009.
9. Boudewyns, V., A.C. O'Donoghue, B. Kelly, et al., ``Influence of
Patient Medication Information Format on Comprehension and
Application of Medication Information: A Randomized, Controlled
Experiment,'' Patient Education and Counseling, 98(12):1592-1599,
2015.
Dated: April 28, 2016.
Leslie Kux,
Associate Commissioner for Policy.
[FR Doc. 2016-10396 Filed 5-3-16; 8:45 am]
BILLING CODE 4164-01-P