Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Medical Conference Attendees' Observations About Prescription Drug Promotion, 37160-37165 [2021-14936]
Download as PDF
37160
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
lotter on DSK11XQN23PROD with NOTICES1
Staff. If you do not wish your name and
contact information to be made publicly
available, you can provide this
information on the cover sheet and not
in the body of your comments and you
must identify this information as
‘‘confidential.’’ Any information marked
as ‘‘confidential’’ will not be disclosed
except in accordance with 21 CFR 10.20
and other applicable disclosure law. For
more information about FDA’s posting
of comments to public dockets, see 80
FR 56469, September 18, 2015, or access
the information at: https://
www.govinfo.gov/content/pkg/FR-201509-18/pdf/2015-23389.pdf.
Docket: For access to the docket to
read background documents or the
electronic and written/paper comments
received, go to https://
www.regulations.gov and insert the
docket number, found in brackets in the
heading of this document, into the
‘‘Search’’ box and follow the prompts
and/or go to the Dockets Management
Staff, 5630 Fishers Lane, Rm. 1061,
Rockville, MD 20852, 240–402–7500.
You may submit comments on any
guidance at any time (see 21 CFR
10.115(g)(5)).
Submit written requests for single
copies of the guidance to the Policy and
Regulations Staff (HFV–6), Center for
Veterinary Medicine, Food and Drug
Administration, 7500 Standish Pl.,
Rockville, MD 20855. Send one selfaddressed adhesive label to assist that
office in processing your requests. See
the SUPPLEMENTARY INFORMATION section
for electronic access to the guidance
document.
The guidance represents the current
thinking of FDA on eligibility criteria
for expanded conditional approval of
new animal drugs. It does not establish
any rights for any person and is not
binding on FDA or the public. You can
use an alternative approach if it satisfies
the requirements of the applicable
statutes and regulations.
II. Paperwork Reduction Act of 1995
While this guidance contains no
collection of information, it does refer to
previously approved FDA collections of
information. Therefore, clearance by the
Office of Management and Budget
(OMB) under the Paperwork Reduction
Act of 1995 (PRA) (44 U.S.C. 3501–
3521) is not required for this guidance.
The previously approved collections of
information are subject to review by
OMB under the PRA. The collections of
information in 21 CFR part 514 have
been approved under OMB control
number 0910–0032.
III. Electronic Access
Persons with access to the internet
may obtain the guidance at either
https://www.fda.gov/AnimalVeterinary/
GuidanceComplianceEnforcement/
GuidanceforIndustry/default.htm,
https://www.fda.gov/regulatoryinformation/search-fda-guidancedocuments, or https://
www.regulations.gov.
Dated: July 8, 2021.
Lauren K. Roth,
Acting Principal Associate Commissioner for
Policy.
[FR Doc. 2021–14938 Filed 7–13–21; 8:45 am]
FOR FURTHER INFORMATION CONTACT:
BILLING CODE 4164–01–P
Christopher Loss, Center for Veterinary
Medicine (HFV–116), Food and Drug
Administration, 7500 Standish Pl.,
Rockville, MD 20855, 240–402–0619,
christopher.loss@fda.hhs.gov.
SUPPLEMENTARY INFORMATION:
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
I. Background
[Docket No. FDA–2020–N–1644]
In the Federal Register of September
30, 2019 (84 FR 51594), FDA published
the notice of availability for a draft
guidance entitled ‘‘Eligibility Criteria for
Expanded Conditional Approval of New
Animal Drugs’’ giving interested
persons until January 28, 2020, to
comment on the draft guidance. FDA
received a few comments on the draft
guidance and those comments were
considered as the guidance was
finalized. Editorial changes were made
to improve clarity. The guidance
announced in this notice finalizes the
draft guidance dated September 2019.
This level 1 guidance is being issued
consistent with FDA’s good guidance
practices regulation (21 CFR 10.115).
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
Food and Drug Administration
Agency Information Collection
Activities; Submission for Office of
Management and Budget Review;
Comment Request; Medical
Conference Attendees’ Observations
About Prescription Drug Promotion
Food and Drug Administration,
Health and Human Services (HHS).
ACTION: Notice.
AGENCY:
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.
SUMMARY:
PO 00000
Frm 00047
Fmt 4703
Sfmt 4703
Submit written comments
(including recommendations) on the
collection of information by August 13,
2021.
ADDRESSES: To ensure that comments on
the information collection are received,
OMB recommends that written
comments be submitted to https://
www.reginfo.gov/public/do/PRAMain.
Find this particular information
collection by selecting ‘‘Currently under
Review—Open for Public Comments’’ or
by using the search function. The title
of this information collection is
‘‘Medical Conference Attendees’
Observations About Prescription Drug
Promotion.’’ Also include the FDA
docket number found in brackets in the
heading of this document.
FOR FURTHER INFORMATION CONTACT: Ila
S. Mizrachi, Office of Operations, Food
and Drug Administration, Three White
Flint North, 10A–12M, 11601
Landsdown St., North Bethesda, MD
20852, 301–796–7726, PRAStaff@
fda.hhs.gov.
DATES:
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:
Medical Conference Attendees’
Observations About Prescription Drug
Promotion
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 (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 Office of Prescription Drug
Promotion’s (OPDP) mission is to
protect the public health by helping to
ensure that prescription drug promotion
is truthful, balanced, and accurately
communicated. OPDP’s research
program provides scientific evidence to
help ensure that our policies related to
prescription drug promotion will have
the greatest benefit to public health.
Toward that end, we have consistently
conducted research to evaluate the
aspects of prescription drug promotion
that are most central to our mission. Our
research focuses in particular on three
main topic areas: Advertising features,
including content and format; target
populations; and research quality.
Through the evaluation of advertising
features, we assess how elements such
E:\FR\FM\14JYN1.SGM
14JYN1
lotter on DSK11XQN23PROD with NOTICES1
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
as graphics, format, and disease and
product characteristics impact the
communication and understanding of
prescription drug risks and benefits.
Focusing on target populations allows
us to evaluate how understanding of
prescription drug risks and benefits may
vary as a function of audience, and our
focus on research quality aims at
maximizing the quality of our research
data through analytical methodology
development and investigation of
sampling and response issues. This
study will inform the first two topic
areas, advertising features and target
populations.
Because we recognize that the
strength of data and the confidence in
the robust nature of the findings is
improved by utilizing the results of
multiple converging studies, we
continue to develop evidence to inform
our thinking. We evaluate the results
from our studies within the broader
context of research and findings from
other sources, and this larger body of
knowledge collectively informs our
policies as well as our research program.
Our research is documented on our
homepage, which can be found at:
https://www.fda.gov/aboutfda/
centersoffices/officeofmedicalproducts
andtobacco/cder/ucm090276.htm. The
website includes links to the latest
Federal Register notices and peerreviewed publications produced by our
office. The website maintains
information on studies we have
conducted, dating back to a survey on
direct-to-consumer advertisements
conducted in 1999.
The current study focuses on
understanding the landscape of
healthcare provider (HCP)-directed
promotion of prescription drugs at
medical conferences in general and,
more specifically, how elements of
pharmaceutical booths in medical
conference exhibit halls impact HCP
attendees’ perceptions of the drugs that
are promoted at those booths. We will
first ask attendees who are prescribers
within different disciplines (primary
care physicians, specialists, nurse
practitioners, and physician assistants)
general questions about their attendance
at medical conferences, including
questions about their motivations for
attending, activities they participate in
(e.g., symposia, poster sessions, social
events, exhibit halls), and their opinions
about the prescription drug treatments
promoted at medical conferences. These
questions will allow us to capture the
viewpoint of prescribers who attend
medical conferences where prescription
treatments are discussed and promoted.
The second part of our study will
allow us to get more detailed
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
information about interactions in
medical conference exhibit halls. A
2006 study found that at least 80
percent of physicians attended at least
1 medical conference each year and
spent an average of 7 hours on the
exhibit hall floor at each event (Ref. 1).
The length of time spent at each booth—
between 12 and 21 minutes (Ref. 1)—
was comparatively longer than detailing
visits in HCP offices, which range from
5 to 10 minutes on average (Refs. 2 and
3). Thus, medical conference exhibit
booths provide opportunities for
pharmaceutical companies to market to
large numbers of HCPs and potentially
engage in more lengthy interactions.
Promotional booths for prescription
drugs and the promotional materials
disseminated at those booths fall within
the regulatory purview of OPDP. As
with other promotional materials for
prescription drugs, pharmaceutical
companies may voluntarily submit draft
versions of their exhibit panels and
exhibit materials for FDA review (Ref.
4). This study is designed to provide
insights to inform the advisory
comments that OPDP provides to
pharmaceutical companies that
voluntarily seek FDA review. OPDP also
monitors prescription drug promotional
booths and materials as part of its
surveillance program. Recent
compliance letters issued by OPDP
described booth or panel displays that
communicated misleading information
regarding drug efficacy and safety,
provided insufficient information on
drug risks, and omitted ‘‘material facts’’
about the promoted drug (Ref. 5). A
primary reason that physicians and
other medical professionals report
visiting specific exhibitors at
conferences is to obtain product
information (Ref. 1), and it is important
that the information provided by
exhibitors to HCPs regarding the risks
and efficacy of prescription medications
not be false or misleading. Thus,
investigating the impact of
pharmaceutical booth promotions
among medical conference attendees
has valuable practical implications for
the public health.
As part of our specific exhibit booth
research, we will simulate interactions
that HCPs may have at medical
conference booths promoting
prescription drugs, so that FDA can
examine the effects of the booth
representative’s background (scientist/
medical professional versus business
professional) and disclosure of data
limitations (present versus absent). In a
recent survey, HCP conference attendees
reported that interacting with company
representatives was the most important
element of their booth visits, followed
PO 00000
Frm 00048
Fmt 4703
Sfmt 4703
37161
by the availability and quality of clinical
information (Ref. 4). Thus, the perceived
credibility of the booth representative
and the availability of information on
data limitations could ultimately inform
HCPs’ perceptions of the risks and
benefits of drugs presented at exhibit
booths and their decisions to prescribe
drugs to patients.
Indeed, literature suggests that
credibility and disclosures are relevant
elements to study in the context of
prescription drug conference booths.
Credibility is linked to extrinsic
(physical attractiveness, power) and
intrinsic (delivery factors, linguistic
cues) factors. For example, one extrinsic
feature of source credibility is similarity
between the source and recipient.
Research on the effects of source
similarity has been mixed, but a classic
field experiment by Brock in 1965 found
that customers buying paint were more
likely to follow recommendations of a
salesperson they perceived as having
painting experiences similar to their
own (Ref. 6). More recent studies have
examined the effects of endorsers with
professional expertise versus those with
product experience on attitudes toward
the brand and promotion (Refs. 7 and 8).
These past studies are relevant to our
manipulations of booth representative
background in this study given that
representatives with a medical/science
background may reflect professional
expertise, whereas representatives with
a business background may reflect
product experience.
There is little empirical evidence on
the impact of disclosing data limitations
during promotional detailing or other
sales promotion. On one hand,
providing important information (e.g.,
key limitations) about the data/drug
should help increase comprehension
and decrease inaccurate or unjustified
interpretations of the data. On the other
hand, seeing the disclosure of data
limitations—essentially tempering the
study findings and providing a sort of
two-sided information that is not
necessarily in favor of the drug’s
effects—may improve the material’s
credibility and appeal by signifying
more transparency on the sponsor’s part
(Ref. 9), and therefore lead to greater
interest in the drug (regardless of
accurate comprehension). Conversely,
not seeing any qualifying or clarifying
information could raise red flags among
providers, resulting in the lowest levels
of perceived credibility. Whether the
booth representative has a medical/
science background or business
background may shape perceptions of
credibility even further, thereby
influencing HCPs’ perceptions of the
drug. Thus, while disclosure of data
E:\FR\FM\14JYN1.SGM
14JYN1
37162
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
limitations and credibility of the booth
representative may have independent
effects on HCPs’ comprehension and
perceptions, these variables could also
interact in their effects.
I. Research Questions
With this background in mind, we
plan to address the issue of how firms
communicate about prescription drugs
from the perspective of medical
conference/exhibit hall attendees.
Specifically, we will ask for attendees’
general observations of:
a. Disclosures or disclaimers
accompanying exhibit hall presentations
and/or symposia (about data limitations,
contrary data, FDA approval status,
financial/affiliation sponsorship, etc.);
b. Publications or references
accompanying the presentation of
information (PI for approved
indications, contrary data references,
etc.);
c. What type of studies are being
reported (real world evidence,
pharmacokinetic/pharmacodynamic
studies, meta-analyses, etc.).
d. Who makes the presentations (field
of study, training); and
e. Where the presentations are made
(poster session, scientific floor, exhibit
hall); and
We will also address exhibit hall
pharmaceutical booth interactions
specifically:
a. How does the presence or absence
of information about the limitations of
data influence perceptions of the
promoted product?
b. How does the background of the
booth representative influence
perceptions of the promoted product?
c. Do these two variables interact?
II. Method
To complete this research, we will
recruit attendees of large medical
conferences in the United States over
the course of 1 year. These conferences
will represent a variety of specialties to
reflect medical areas that have
prescription treatments that may be
promoted to HCPs. Specifically, we will
enroll HCPs who attended one of 12
selected medical conferences into an
online survey within 7 days of
conference attendance. Exhibit 1
summarizes our approach to: (1)
Determining the conference sampling
frame; (2) determining the attendee
sampling frame; and (3) recruiting and
enrolling the target sample in the online
survey.
Exhibit 1. Sampling Frame and Participant Recruitment
Process
.
-----*.
Conference Sampling Frame
Attendee Sampling
Step 1.
Step 2. Conduct Environmental Scan of Conferences
Step 3. Apply Conference 1:ligibility Criteria
Step 4. Select Conferences for Sampling/Recruitment
·---.......
Step 5. Develop Conference Attendee Erigibility Criteria:
~ Step ti. Characterize the Attendee Sampling Frame
Frame
1---,...
·Step.7. Create and Place Recruitment Advertisements
1 Step 8Aicreen Potential Participants
Participant Recruitment and
Step 9.Randomly AssigrrParticipants to· Experimental
Conditions
Enrollment
In the first step, we will select
conferences that focused on therapeutic
areas that have the following attributes:
• High number of currently promoted
branded medications;
Select Priority Therapeutic Areas
• high volume of prescriptions
written;
• large patient population; and
• high amount of new drug
development and promotional
spending.
Exhibit 2 shows the final criterion for
conference inclusion. Conferences that
meet these criteria will be selected
based on an environmental scan.
EXHIBIT 2—CONFERENCE ELIGIBILITY CRITERIA
Parameters
Therapeutic area ....................................................
Conference attendance ..........................................
Target audience .....................................................
Event date ..............................................................
Event location ........................................................
Following conference selection,
medical conference attendees at each
conference will be randomly selected,
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
Associated with one of the prioritized therapeutic areas.
Estimated attendance of 5,000 or more individuals.
Focused on prescribers and clinicians (e.g., not insurers).
Scheduled during August 2021–August 2022.
Domestic (within United States).
invited to participate, and screened to
ensure they are HCPs with prescribing
authority who responded to the survey
PO 00000
Frm 00049
Fmt 4703
Sfmt 4703
invitation within 7 days of attending the
target conference. HCPs will be limited
to physicians, nurse practitioners, and
E:\FR\FM\14JYN1.SGM
14JYN1
EN14JY21.000
lotter on DSK11XQN23PROD with NOTICES1
Criterion
37163
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
physician assistants who spend 20
percent or more time in direct patient
care, are able to read and speak English,
are not currently employed by the
Federal government or a pharmaceutical
company (not including occasional
consulting), and have not participated
in another wave of the project.
The online survey will be broken into
two main parts: (1) A cross-sectional
survey designed to capture HCP
observations from the medical
conference and (2) an experimental
study designed to assess how data
disclosures and exhibit booth
representative background influence
HCP perceptions of promoted
prescription drugs. The cross-sectional
part of the survey will contain a series
of close- and open-ended questions. The
experimental study part of the survey
will ask participants to view a brief
video simulating a conference exhibit
hall interaction between an HCP
attendee and a booth employee and then
answer questions about a fictitious
prescription drug featured in the video.
Exhibit 3 shows our proposed study
design and sample size across 12
conferences.
EXHIBIT 3—STUDY DESIGN AND TARGET SAMPLE SIZES
Booth employee background
Disclosure
Total
lotter on DSK11XQN23PROD with NOTICES1
Business
Medical
Present .........................................................................................................................................
Absent ..........................................................................................................................................
n=92
n=92
n=92
n=92
184
184
Total ......................................................................................................................................
184
184
368
In the Federal Register of September
18, 2020 (85 FR 58366), FDA published
a 60-day notice requesting public
comment on the proposed collection of
information. FDA received six
submissions that were PRA-related. One
submission (https://
www.regulations.gov/document/FDA2020-N-1644-0005) was outside the
scope of the research and is not
addressed further. Within the remaining
five submissions, FDA received
multiple comments that the Agency has
addressed below. For brevity, some
public comments are paraphrased and
therefore may not include the exact
language used by the commenter. We
assure commenters that the entirety of
their comments was considered even if
not fully captured by our paraphrasing
in this document. The following
acronyms are used here: HCP =
healthcare provider; FDA = Food and
Drug Administration; OPDP = FDA’s
Office of Prescription Drug Promotion.
(Comment 1) Five comments
expressed support for conducting this
research.
(Response 1) Thank you.
(Comment 2) Three comments noted
that changes to the research will be
necessary due to changes in medical
conferences as a result of the emergence
of the COVID–19 pandemic, such as the
move to all-virtual conferences.
(Response 2) We agree with these
comments. Section 1 of the
questionnaire (Video observation) is
unaffected by whether participants have
recently attended a conference, so we
have not changed this section. Section
3 (Typical Conference Behaviors) is also
unaffected by recent conference
attendance. However, we added an
instruction that participants should
answer about their behavior prior to
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
COVID–19 restrictions. Most of the
questions in Section 4 (Participant
Characteristics) are unaffected by recent
conference attendance. However, we
updated questions about patient load
and prescription volume to include both
in-person and telemedicine visits.
Section 2 (Recent Conference Behavior)
does assume participants have recently
attended a conference. We have
replaced some of the questions that are
less likely to be relevant (e.g., receipt of
materials) with open-ended questions
asking about the exhibit hall experience
and interactions with pharmaceutical
company representatives during a
virtual conference.
(Comment 3) One comment suggested
adding a control arm comprised of
physicians who have not attended a
medical conference during the same
period and asking them about their
perceptions of the same products in
order to determine to what extent
medical conferences are influencing
physician perceptions of products.
(Response 3) This comment is outside
the scope of the current research.
Researchers may want to explore
additional questions in this area for
future studies.
(Comment 4) One comment suggested
that because the video is not interactive,
it may not capture all possible questions
that a conference attendee may have.
(Response 4) The comment is correct
that the video consists of a prerecorded
interaction between a conference
attendee and a booth representative. We
recognize that this does not cover all
possible communications at a
conference. We appreciate the
suggestion about the use of interactive
simulation, but it would disrupt the
experimental design by creating
unnecessary variation in the stimuli.
PO 00000
Frm 00050
Fmt 4703
Sfmt 4703
The limitations of the current method
will be transparent in the dissemination
of our findings.
(Comment 5) Two comments
mentioned that, if we are concerned
about subject bias, differences in age,
gender, and race/ethnicity between the
pharmaceutical representative and the
prescriber in the video should be
controlled for.
(Response 5) The videos are identical
in every way except for the job
description of the booth representative
and whether a disclosure is present to
the data described. This means that not
only are the actors the same, but almost
all footage in the video is the same.
Additionally, participants will be
randomly assigned to experimental
conditions. Thus, age, gender, and race/
ethnicity will not factor into our
assessment of whether a booth
representative’s job description or the
presence of a disclosure influences
participant responses.
(Comment 6) Two comments
cautioned FDA against drawing
conclusions about all promotional
details based on survey responses for
one video. These comments suggested
that FDA use multiple videos, rather
than just one, to depict different
approaches to promotion and re-design
the study to conduct a post-conference
message recall study to allow FDA to
better meet the objectives of the study.
(Response 6) The current study is
largely a survey about medical
conference attendance in general and
more specifically at a recent conference.
Our objective, as outlined in the text of
the 60-day notice, is to use those
questions to assess self-reported
opinions about participants’ experiences
at a variety of conferences. Within the
study is an embedded experimental
E:\FR\FM\14JYN1.SGM
14JYN1
lotter on DSK11XQN23PROD with NOTICES1
37164
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
manipulation to address two very
specific questions: whether the
credentials of a booth representative
make a difference in terms of the
observers’ perceptions of the promoted
product, and whether a disclosure of
information is processed by observers.
In this part, participants will see one of
four videos that are identical except for
the credentials of the booth
representative and the presence or
absence of a disclosure. FDA will not
use the video to generalize beyond these
questions. Because participants will be
randomly assigned to video conditions,
we will be able to make causal claims—
but only about the specific items
(credentials and disclosure) we vary.
(Comment 7) One comment requested
that we provide the public with an
opportunity to preview and comment on
the videos to be used in future research
proposals.
(Response 7) Our full stimuli are
under development during the PRA
process. We do not make draft stimuli
public during this time because of
concerns that this may contaminate our
participant pool and compromise our
research. In our research proposals, we
describe the purpose of the study, the
design, the population of interest, and
the estimated burden.
(Comment 8) One comment
mentioned that although limiting
participants to those who respond to the
survey within 7 days creates a selection
bias, it is a feasible method. The
comment suggested that we also screen
for amount of time participants spent on
the exhibit hall floor, rather than relying
on average numbers of hours spent at
exhibition halls.
(Response 8) We are limiting the
sample to participants who attended a
medical conference within 7 days to
minimize retrospective errors that may
occur as time passes. We appreciate the
suggestion that we add a question about
how much time is spent at the
exhibition hall, and we have
incorporated it into the questionnaire.
(Comment 9) One comment suggested
that, given the international scope of
many conferences, the screener should
ensure that HCPs practice in the United
States.
(Response 9) Our sample will be
limited to U.S.-based HCPs with
prescribing authority.
(Comment 10) One comment
suggested that specific knowledge of
OPDP regulatory requirements may be
limited and, if known, it may increase
credibility of booth representatives. The
commenter suggests adding questions
about regulatory knowledge.
(Response 10) Past OPDP studies have
examined HCPs’ familiarity with
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
promotional regulation (e.g., OMB
control number 0910–0869). We have
consistently found that only a small
percentage of providers know whether
FDA regulates prescription drug
promotion, and we believe even fewer
would have specific knowledge of
OPDP’s particular regulatory authorities.
Given that we have investigated this
topic in the past and we find most
providers to be unfamiliar with
regulatory roles, we will leave such
questions out of the study to reduce
burden.
(Comment 11) One comment
suggested the inclusion of additional
questions about the perceived
credibility of the booth representative,
the likelihood of recommending the
prescription drug, or the desire to
conduct further inquiries for the
product.
(Response 11) We have included
questions about booth representative
credibility and intention to prescribe.
(Comment 12) One comment
suggested that it would be useful to add
questions about the participants’
backgrounds, such as familiarity with
prescription drug promotion, age,
specialty, personal medical/professional
school debt, exposure to pharmaceutical
marketing practices, and whether they
practice in an urban or rural area.
(Response 12) We have questions
about age, medical specialty, and
exposure to pharmaceutical marketing
practices. We will include a question
about the rural versus urban location of
their practices. We decline to ask about
personal medical school debt because it
is not clear how this will influence
pharmaceutical promotions in a
conference exhibit hall.
(Comment 13) One comment
suggested adding questions about
aspects of promotional exhibit halls
other than the booth representative.
(Response 13) This comment is
outside the scope of the current
research. Researchers may want to
explore additional questions in this area
for future studies.
(Comment 14) One comment noted
that it would be helpful to track whether
advertisements outside of the exhibit
hall encouraged providers to visit
certain booths within the exhibit halls.
(Response 14) This comment is
outside the scope of the current
research. Researchers may want to
explore additional questions in this area
for future studies.
(Comment 15) One comment
recommended keeping the focus of
Section 2 (recent conference behaviors)
on general conference behaviors and
moving all product perception questions
to Section 1.
PO 00000
Frm 00051
Fmt 4703
Sfmt 4703
(Response 15) Section 1 involves the
specific manipulation of booth
representative credentials and the
presence/absence of a disclosure.
Section 2 involves asking participants
about a recent conference experience.
The advantage of this approach is that
we can get more specific information
not influenced by retrospective
guessing. The opportunity to ask
specific questions is one of the strengths
of the current study.
(Comment 16) One comment
mentioned that the questions make use
of the term ‘‘booth,’’ while the Federal
Register notice speaks to ‘‘promotional
booth’’ and suggested that the survey
questions use the term ‘‘promotional
booth’’ for clarity and consistency.
(Response 16) We have made this
change.
(Comment 17) One comment
mentioned that the questions use the
term ‘‘industry representative’’ or ‘‘drug
representative’’ and suggested the
survey employ the term ‘‘industry
representative’’ exclusively to ensure
clarity and consistency.
(Response 17) We have revised the
questionnaire to consistently use the
term ‘‘industry representative.’’
(Comment 18) One comment
suggested we change the wording of
questions using the term ‘‘exhibit hall’’
to refer instead to ‘‘promotional booths
located in the exhibit hall,’’ which is
more focused.
(Response 18) We have made this
change.
(Comment 19) One comment
suggested that for Questions 6–11, the
survey taker’s responses can be
influenced by other factors not
necessarily related to the content
provided in the video, thus leading to
inconclusive results about the video
presented.
(Response 19) Questions 6–11 refer to
the experimental manipulation in the
video (see Response 6). Because we will
have random assignment to condition
and the only differences in the videos
will be the credentials of the booth
representative and the presence or
absence of a disclosure, we will be able
to make causal claims if we see
differences in responses across
conditions.
(Comment 20) One comment
suggested that to eliminate the risk of
bias in the survey questions related to
safety and efficacy, study participants
should be asked whether they think that
the promoted drug is safer and whether
they think that the promoted drug is
more efficacious as compared to another
drug.
(Response 20) This comment appears
to refer to Questions 8 and 9. These are
E:\FR\FM\14JYN1.SGM
14JYN1
Federal Register / Vol. 86, No. 132 / Wednesday, July 14, 2021 / Notices
validated questions that have been used
in previous studies (Ref. 10).
Development and validation of
prescription drug risk, efficacy, and
benefit perception measures in the
context of direct-to-consumer
prescription drug advertising. Research
in Social and Administrative
Pharmacy). Moreover, the scale ranges
from ‘‘Strongly Agree’’ to ‘‘Strongly
Disagree,’’ so no bias is implied.
(Comment 21) One comment
suggested that Questions 13 and 14 are
specific to one risk and that this risk
may not pertain to all situations, such
as treatments for serious and lifethreatening conditions. The comment
expressed confusion regarding how
conclusions from these questions can be
applied to all drugs promoted at a
convention.
(Response 21) We specifically ask
questions about this risk because this is
the risk that relates to the disclosure
manipulation. These questions will be
used to determine if the presence of a
disclosure influences participants’
responses to the relevant information in
the ad.
(Comment 22) One comment
suggested that Questions 22 and 23
should be reworded to define what part
of the conference (poster session,
exhibit hall, oral sessions, etc.) the
words ‘‘conference sessions’’ are
referring to.
(Response 22) We have now specified
‘‘oral and poster sessions’’ in these
questions.
(Comment 23) One comment
suggested that followup questions
should be added for participants that
answer ‘‘Yes’’ to Question 24 as follows:
What was the background of the
person who made this presentation?
• Answer Options: Scientific
background, Business background.
What part of the conference was this
presentation presented at?
• Answer Options: Symposia/Oral
sessions, Workshops, Poster sessions,
Exhibit hall.
(Response 23) We considered adding
these questions to the questionnaire.
37165
However, after adapting the survey for
a current and post-COVID–19 world,
these questions were ultimately not
included so that the information
collection could stay within the
proposed burden estimate.
(Comment 24) One comment
suggested that Question 30 should be
reworded so that it is specific to the
particular types of materials checked in
Question 29.
(Response 24) We have removed
Question 30 from the questionnaire due
to time constraints.
(Comment 25) One comment
recommended the addition of a choice
that reads, ‘‘met with the sales
representative virtually,’’ for Question
51, as this has been occurring more
frequently during the COVID–19
pandemic.
(Response 25) This response option
was added.
FDA estimates the burden of this
collection of information as follows:
TABLE 1—ESTIMATED ANNUAL REPORTING BURDEN 1
Number of
respondents
Total annual
respondents
Average burden
per response
Total
hours
Screener .......................................................................
Pretest ..........................................................................
Main test .......................................................................
933
25
368
1
1
1
933
25
368
.08 (5 minutes) ......
.33 (20 minutes) ....
.33 (20 minutes) ....
74.64
8.25
121.44
Total ......................................................................
........................
........................
........................
...............................
204.33
1 There
are no capital costs or operating and maintenance costs associated with this collection of information.
III. References
lotter on DSK11XQN23PROD with NOTICES1
Number of
responses per
respondent
The following references marked with
an asterisk (*) are on display at the
Dockets Management Staff (HFA–305),
Food and Drug Administration, 5630
Fishers Lane, Rm. 1061, Rockville, MD
20852, 240–402–7500) and are available
for viewing by interested persons
between 9 a.m. and 4 p.m., Monday
through Friday; they also are available
electronically at https://
www.regulations.gov. References
without asterisks are not on public
display at https://www.regulations.gov
because they have copyright restriction.
Some may be available at the website
address, if listed. References without
asterisks are available for viewing only
at the Dockets Management Staff. FDA
has verified the website addresses, as of
the date this document publishes in the
Federal Register, but websites are
subject to change over time.
1. Mack, J. (2006, March). ‘‘Effective
Physician Marketing at Medical Meeting
Exhibits.’’ Pharma Marketing News, 5(3).
2. * Industry Standard Report. (2014).
VerDate Sep<11>2014
17:49 Jul 13, 2021
Jkt 253001
‘‘Pharmaceutical Detailing: In-Person vs.
Electronic vs. Phone.’’ Retrieved from
https://www.isrreports.com/wp-content/
uploads/2014/08/ISR-PharmaceuticalDetailing-In-Person-vs.-Electronic-vs.Phone-Preview-Aug2014.pdf.
3. * Steinman, M.A., G.M. Harper, M.M.
Chren, et al. (2007, April).
‘‘Characteristics and Impact of Drug
Detailing for Gabapentin.’’ PLoS Med,
4(4), e134. https://dx.doi.org/10.1371/
journal.pmed.0040134.
4. * Adler, D., Manager Marketing Analytics,
A. Sherman, Client Services, and M.
Walz. (2017). ‘‘Medical Conference
Presence: Is it Worth it for your Brand?’’
Retrieved from https://
www.pharmavoice.com/article/2017-9medical-conferences/.
5. * FDA. Warning letters and notice of
violation letters to pharmaceutical
companies. Retrieved from https://
www.fda.gov/drugs/enforcementactivities-fda/warning-letters-and-noticeviolation-letters-pharmaceuticalcompanies.
6. Brock, T.C. (1965, June). ‘‘CommunicatorRecipient Similarity and Decision
Change.’’ Journal of Personality & Social
Psychology, 1, 650–654.
7. Braunsberger, K. and J.M. Munch (1998).
PO 00000
Frm 00052
Fmt 4703
Sfmt 9990
‘‘Source Expertise Versus Experience
Effects in Hospital Advertising.’’ Journal
of Services Marketing, 12(1), 23–38.
8. Siemens, J.C., S. Smith, D. Fisher, and T.D.
Jensen (2008). ‘‘Product Expertise Versus
Professional Expertise: Congruency
Between an Endorser’s Chosen
Profession and the Endorsed Product.’’
Journal of Targeting, Measurement and
Analysis for Marketing, 16(3), 159–168.
9. Pechmann, C. (1992). ‘‘Predicting When
Two-Sided Ads Will Be More Effective
Than One-Sided Ads: The Role of
Correlational and Correspondent
Inferences.’’ Journal of Marketing
Research, 29(4), 441–453.
10. Kelly, B.J., D.J. Rupert, K.J. Aikin, et al.
(2021). ‘‘Development and Validation of
Prescription Drug Risk, Efficacy, and
Benefit Perception Measures in the
Context of Direct-to-Consumer
Prescription Drug Advertising.’’
Research in Social and Administrative
Pharmacy, 17(5), 942–955.
Dated: July 7, 2021.
Lauren K. Roth,
Acting Principal Associate Commissioner for
Policy.
[FR Doc. 2021–14936 Filed 7–13–21; 8:45 am]
BILLING CODE 4164–01–P
E:\FR\FM\14JYN1.SGM
14JYN1
Agencies
[Federal Register Volume 86, Number 132 (Wednesday, July 14, 2021)]
[Notices]
[Pages 37160-37165]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-14936]
-----------------------------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA-2020-N-1644]
Agency Information Collection Activities; Submission for Office
of Management and Budget Review; Comment Request; Medical Conference
Attendees' Observations About Prescription Drug Promotion
AGENCY: Food and Drug Administration, Health and Human Services (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: Submit written comments (including recommendations) on the
collection of information by August 13, 2021.
ADDRESSES: To ensure that comments on the information collection are
received, OMB recommends that written comments be submitted to https://www.reginfo.gov/public/do/PRAMain. Find this particular information
collection by selecting ``Currently under Review--Open for Public
Comments'' or by using the search function. The title of this
information collection is ``Medical Conference Attendees' Observations
About Prescription Drug Promotion.'' Also include the FDA docket number
found in brackets in the heading of this document.
FOR FURTHER INFORMATION CONTACT: Ila S. Mizrachi, Office of Operations,
Food and Drug Administration, Three White Flint North, 10A-12M, 11601
Landsdown St., North Bethesda, MD 20852, 301-796-7726,
[email protected].
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.
Medical Conference Attendees' Observations About Prescription Drug
Promotion
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 (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 Office of Prescription Drug Promotion's (OPDP) mission is to
protect the public health by helping to ensure that prescription drug
promotion is truthful, balanced, and accurately communicated. OPDP's
research program provides scientific evidence to help ensure that our
policies related to prescription drug promotion will have the greatest
benefit to public health. Toward that end, we have consistently
conducted research to evaluate the aspects of prescription drug
promotion that are most central to our mission. Our research focuses in
particular on three main topic areas: Advertising features, including
content and format; target populations; and research quality. Through
the evaluation of advertising features, we assess how elements such
[[Page 37161]]
as graphics, format, and disease and product characteristics impact the
communication and understanding of prescription drug risks and
benefits. Focusing on target populations allows us to evaluate how
understanding of prescription drug risks and benefits may vary as a
function of audience, and our focus on research quality aims at
maximizing the quality of our research data through analytical
methodology development and investigation of sampling and response
issues. This study will inform the first two topic areas, advertising
features and target populations.
Because we recognize that the strength of data and the confidence
in the robust nature of the findings is improved by utilizing the
results of multiple converging studies, we continue to develop evidence
to inform our thinking. We evaluate the results from our studies within
the broader context of research and findings from other sources, and
this larger body of knowledge collectively informs our policies as well
as our research program. Our research is documented on our homepage,
which can be found at: https://www.fda.gov/aboutfda/centersoffices/officeofmedicalproductsandtobacco/cder/ucm090276.htm. The website
includes links to the latest Federal Register notices and peer-reviewed
publications produced by our office. The website maintains information
on studies we have conducted, dating back to a survey on direct-to-
consumer advertisements conducted in 1999.
The current study focuses on understanding the landscape of
healthcare provider (HCP)-directed promotion of prescription drugs at
medical conferences in general and, more specifically, how elements of
pharmaceutical booths in medical conference exhibit halls impact HCP
attendees' perceptions of the drugs that are promoted at those booths.
We will first ask attendees who are prescribers within different
disciplines (primary care physicians, specialists, nurse practitioners,
and physician assistants) general questions about their attendance at
medical conferences, including questions about their motivations for
attending, activities they participate in (e.g., symposia, poster
sessions, social events, exhibit halls), and their opinions about the
prescription drug treatments promoted at medical conferences. These
questions will allow us to capture the viewpoint of prescribers who
attend medical conferences where prescription treatments are discussed
and promoted.
The second part of our study will allow us to get more detailed
information about interactions in medical conference exhibit halls. A
2006 study found that at least 80 percent of physicians attended at
least 1 medical conference each year and spent an average of 7 hours on
the exhibit hall floor at each event (Ref. 1). The length of time spent
at each booth--between 12 and 21 minutes (Ref. 1)--was comparatively
longer than detailing visits in HCP offices, which range from 5 to 10
minutes on average (Refs. 2 and 3). Thus, medical conference exhibit
booths provide opportunities for pharmaceutical companies to market to
large numbers of HCPs and potentially engage in more lengthy
interactions.
Promotional booths for prescription drugs and the promotional
materials disseminated at those booths fall within the regulatory
purview of OPDP. As with other promotional materials for prescription
drugs, pharmaceutical companies may voluntarily submit draft versions
of their exhibit panels and exhibit materials for FDA review (Ref. 4).
This study is designed to provide insights to inform the advisory
comments that OPDP provides to pharmaceutical companies that
voluntarily seek FDA review. OPDP also monitors prescription drug
promotional booths and materials as part of its surveillance program.
Recent compliance letters issued by OPDP described booth or panel
displays that communicated misleading information regarding drug
efficacy and safety, provided insufficient information on drug risks,
and omitted ``material facts'' about the promoted drug (Ref. 5). A
primary reason that physicians and other medical professionals report
visiting specific exhibitors at conferences is to obtain product
information (Ref. 1), and it is important that the information provided
by exhibitors to HCPs regarding the risks and efficacy of prescription
medications not be false or misleading. Thus, investigating the impact
of pharmaceutical booth promotions among medical conference attendees
has valuable practical implications for the public health.
As part of our specific exhibit booth research, we will simulate
interactions that HCPs may have at medical conference booths promoting
prescription drugs, so that FDA can examine the effects of the booth
representative's background (scientist/medical professional versus
business professional) and disclosure of data limitations (present
versus absent). In a recent survey, HCP conference attendees reported
that interacting with company representatives was the most important
element of their booth visits, followed by the availability and quality
of clinical information (Ref. 4). Thus, the perceived credibility of
the booth representative and the availability of information on data
limitations could ultimately inform HCPs' perceptions of the risks and
benefits of drugs presented at exhibit booths and their decisions to
prescribe drugs to patients.
Indeed, literature suggests that credibility and disclosures are
relevant elements to study in the context of prescription drug
conference booths. Credibility is linked to extrinsic (physical
attractiveness, power) and intrinsic (delivery factors, linguistic
cues) factors. For example, one extrinsic feature of source credibility
is similarity between the source and recipient. Research on the effects
of source similarity has been mixed, but a classic field experiment by
Brock in 1965 found that customers buying paint were more likely to
follow recommendations of a salesperson they perceived as having
painting experiences similar to their own (Ref. 6). More recent studies
have examined the effects of endorsers with professional expertise
versus those with product experience on attitudes toward the brand and
promotion (Refs. 7 and 8). These past studies are relevant to our
manipulations of booth representative background in this study given
that representatives with a medical/science background may reflect
professional expertise, whereas representatives with a business
background may reflect product experience.
There is little empirical evidence on the impact of disclosing data
limitations during promotional detailing or other sales promotion. On
one hand, providing important information (e.g., key limitations) about
the data/drug should help increase comprehension and decrease
inaccurate or unjustified interpretations of the data. On the other
hand, seeing the disclosure of data limitations--essentially tempering
the study findings and providing a sort of two-sided information that
is not necessarily in favor of the drug's effects--may improve the
material's credibility and appeal by signifying more transparency on
the sponsor's part (Ref. 9), and therefore lead to greater interest in
the drug (regardless of accurate comprehension). Conversely, not seeing
any qualifying or clarifying information could raise red flags among
providers, resulting in the lowest levels of perceived credibility.
Whether the booth representative has a medical/science background or
business background may shape perceptions of credibility even further,
thereby influencing HCPs' perceptions of the drug. Thus, while
disclosure of data
[[Page 37162]]
limitations and credibility of the booth representative may have
independent effects on HCPs' comprehension and perceptions, these
variables could also interact in their effects.
I. Research Questions
With this background in mind, we plan to address the issue of how
firms communicate about prescription drugs from the perspective of
medical conference/exhibit hall attendees. Specifically, we will ask
for attendees' general observations of:
a. Disclosures or disclaimers accompanying exhibit hall
presentations and/or symposia (about data limitations, contrary data,
FDA approval status, financial/affiliation sponsorship, etc.);
b. Publications or references accompanying the presentation of
information (PI for approved indications, contrary data references,
etc.);
c. What type of studies are being reported (real world evidence,
pharmacokinetic/pharmacodynamic studies, meta-analyses, etc.).
d. Who makes the presentations (field of study, training); and
e. Where the presentations are made (poster session, scientific
floor, exhibit hall); and
We will also address exhibit hall pharmaceutical booth interactions
specifically:
a. How does the presence or absence of information about the
limitations of data influence perceptions of the promoted product?
b. How does the background of the booth representative influence
perceptions of the promoted product?
c. Do these two variables interact?
II. Method
To complete this research, we will recruit attendees of large
medical conferences in the United States over the course of 1 year.
These conferences will represent a variety of specialties to reflect
medical areas that have prescription treatments that may be promoted to
HCPs. Specifically, we will enroll HCPs who attended one of 12 selected
medical conferences into an online survey within 7 days of conference
attendance. Exhibit 1 summarizes our approach to: (1) Determining the
conference sampling frame; (2) determining the attendee sampling frame;
and (3) recruiting and enrolling the target sample in the online
survey.
[GRAPHIC] [TIFF OMITTED] TN14JY21.000
In the first step, we will select conferences that focused on
therapeutic areas that have the following attributes:
High number of currently promoted branded medications;
high volume of prescriptions written;
large patient population; and
high amount of new drug development and promotional
spending.
Exhibit 2 shows the final criterion for conference inclusion.
Conferences that meet these criteria will be selected based on an
environmental scan.
Exhibit 2--Conference Eligibility Criteria
------------------------------------------------------------------------
Criterion Parameters
------------------------------------------------------------------------
Therapeutic area.................. Associated with one of the
prioritized therapeutic areas.
Conference attendance............. Estimated attendance of 5,000 or
more individuals.
Target audience................... Focused on prescribers and
clinicians (e.g., not insurers).
Event date........................ Scheduled during August 2021-August
2022.
Event location.................... Domestic (within United States).
------------------------------------------------------------------------
Following conference selection, medical conference attendees at
each conference will be randomly selected, invited to participate, and
screened to ensure they are HCPs with prescribing authority who
responded to the survey invitation within 7 days of attending the
target conference. HCPs will be limited to physicians, nurse
practitioners, and
[[Page 37163]]
physician assistants who spend 20 percent or more time in direct
patient care, are able to read and speak English, are not currently
employed by the Federal government or a pharmaceutical company (not
including occasional consulting), and have not participated in another
wave of the project.
The online survey will be broken into two main parts: (1) A cross-
sectional survey designed to capture HCP observations from the medical
conference and (2) an experimental study designed to assess how data
disclosures and exhibit booth representative background influence HCP
perceptions of promoted prescription drugs. The cross-sectional part of
the survey will contain a series of close- and open-ended questions.
The experimental study part of the survey will ask participants to view
a brief video simulating a conference exhibit hall interaction between
an HCP attendee and a booth employee and then answer questions about a
fictitious prescription drug featured in the video. Exhibit 3 shows our
proposed study design and sample size across 12 conferences.
Exhibit 3--Study Design and Target Sample Sizes
----------------------------------------------------------------------------------------------------------------
Booth employee background
Disclosure -------------------------------- Total
Business Medical
----------------------------------------------------------------------------------------------------------------
Present......................................................... n=92 n=92 184
Absent.......................................................... n=92 n=92 184
-----------------------------------------------
Total....................................................... 184 184 368
----------------------------------------------------------------------------------------------------------------
In the Federal Register of September 18, 2020 (85 FR 58366), FDA
published a 60-day notice requesting public comment on the proposed
collection of information. FDA received six submissions that were PRA-
related. One submission (https://www.regulations.gov/document/FDA-2020-N-1644-0005) was outside the scope of the research and is not addressed
further. Within the remaining five submissions, FDA received multiple
comments that the Agency has addressed below. For brevity, some public
comments are paraphrased and therefore may not include the exact
language used by the commenter. We assure commenters that the entirety
of their comments was considered even if not fully captured by our
paraphrasing in this document. The following acronyms are used here:
HCP = healthcare provider; FDA = Food and Drug Administration; OPDP =
FDA's Office of Prescription Drug Promotion.
(Comment 1) Five comments expressed support for conducting this
research.
(Response 1) Thank you.
(Comment 2) Three comments noted that changes to the research will
be necessary due to changes in medical conferences as a result of the
emergence of the COVID-19 pandemic, such as the move to all-virtual
conferences.
(Response 2) We agree with these comments. Section 1 of the
questionnaire (Video observation) is unaffected by whether participants
have recently attended a conference, so we have not changed this
section. Section 3 (Typical Conference Behaviors) is also unaffected by
recent conference attendance. However, we added an instruction that
participants should answer about their behavior prior to COVID-19
restrictions. Most of the questions in Section 4 (Participant
Characteristics) are unaffected by recent conference attendance.
However, we updated questions about patient load and prescription
volume to include both in-person and telemedicine visits. Section 2
(Recent Conference Behavior) does assume participants have recently
attended a conference. We have replaced some of the questions that are
less likely to be relevant (e.g., receipt of materials) with open-ended
questions asking about the exhibit hall experience and interactions
with pharmaceutical company representatives during a virtual
conference.
(Comment 3) One comment suggested adding a control arm comprised of
physicians who have not attended a medical conference during the same
period and asking them about their perceptions of the same products in
order to determine to what extent medical conferences are influencing
physician perceptions of products.
(Response 3) This comment is outside the scope of the current
research. Researchers may want to explore additional questions in this
area for future studies.
(Comment 4) One comment suggested that because the video is not
interactive, it may not capture all possible questions that a
conference attendee may have.
(Response 4) The comment is correct that the video consists of a
prerecorded interaction between a conference attendee and a booth
representative. We recognize that this does not cover all possible
communications at a conference. We appreciate the suggestion about the
use of interactive simulation, but it would disrupt the experimental
design by creating unnecessary variation in the stimuli. The
limitations of the current method will be transparent in the
dissemination of our findings.
(Comment 5) Two comments mentioned that, if we are concerned about
subject bias, differences in age, gender, and race/ethnicity between
the pharmaceutical representative and the prescriber in the video
should be controlled for.
(Response 5) The videos are identical in every way except for the
job description of the booth representative and whether a disclosure is
present to the data described. This means that not only are the actors
the same, but almost all footage in the video is the same.
Additionally, participants will be randomly assigned to experimental
conditions. Thus, age, gender, and race/ethnicity will not factor into
our assessment of whether a booth representative's job description or
the presence of a disclosure influences participant responses.
(Comment 6) Two comments cautioned FDA against drawing conclusions
about all promotional details based on survey responses for one video.
These comments suggested that FDA use multiple videos, rather than just
one, to depict different approaches to promotion and re-design the
study to conduct a post-conference message recall study to allow FDA to
better meet the objectives of the study.
(Response 6) The current study is largely a survey about medical
conference attendance in general and more specifically at a recent
conference. Our objective, as outlined in the text of the 60-day
notice, is to use those questions to assess self-reported opinions
about participants' experiences at a variety of conferences. Within the
study is an embedded experimental
[[Page 37164]]
manipulation to address two very specific questions: whether the
credentials of a booth representative make a difference in terms of the
observers' perceptions of the promoted product, and whether a
disclosure of information is processed by observers. In this part,
participants will see one of four videos that are identical except for
the credentials of the booth representative and the presence or absence
of a disclosure. FDA will not use the video to generalize beyond these
questions. Because participants will be randomly assigned to video
conditions, we will be able to make causal claims--but only about the
specific items (credentials and disclosure) we vary.
(Comment 7) One comment requested that we provide the public with
an opportunity to preview and comment on the videos to be used in
future research proposals.
(Response 7) Our full stimuli are under development during the PRA
process. We do not make draft stimuli public during this time because
of concerns that this may contaminate our participant pool and
compromise our research. In our research proposals, we describe the
purpose of the study, the design, the population of interest, and the
estimated burden.
(Comment 8) One comment mentioned that although limiting
participants to those who respond to the survey within 7 days creates a
selection bias, it is a feasible method. The comment suggested that we
also screen for amount of time participants spent on the exhibit hall
floor, rather than relying on average numbers of hours spent at
exhibition halls.
(Response 8) We are limiting the sample to participants who
attended a medical conference within 7 days to minimize retrospective
errors that may occur as time passes. We appreciate the suggestion that
we add a question about how much time is spent at the exhibition hall,
and we have incorporated it into the questionnaire.
(Comment 9) One comment suggested that, given the international
scope of many conferences, the screener should ensure that HCPs
practice in the United States.
(Response 9) Our sample will be limited to U.S.-based HCPs with
prescribing authority.
(Comment 10) One comment suggested that specific knowledge of OPDP
regulatory requirements may be limited and, if known, it may increase
credibility of booth representatives. The commenter suggests adding
questions about regulatory knowledge.
(Response 10) Past OPDP studies have examined HCPs' familiarity
with promotional regulation (e.g., OMB control number 0910-0869). We
have consistently found that only a small percentage of providers know
whether FDA regulates prescription drug promotion, and we believe even
fewer would have specific knowledge of OPDP's particular regulatory
authorities. Given that we have investigated this topic in the past and
we find most providers to be unfamiliar with regulatory roles, we will
leave such questions out of the study to reduce burden.
(Comment 11) One comment suggested the inclusion of additional
questions about the perceived credibility of the booth representative,
the likelihood of recommending the prescription drug, or the desire to
conduct further inquiries for the product.
(Response 11) We have included questions about booth representative
credibility and intention to prescribe.
(Comment 12) One comment suggested that it would be useful to add
questions about the participants' backgrounds, such as familiarity with
prescription drug promotion, age, specialty, personal medical/
professional school debt, exposure to pharmaceutical marketing
practices, and whether they practice in an urban or rural area.
(Response 12) We have questions about age, medical specialty, and
exposure to pharmaceutical marketing practices. We will include a
question about the rural versus urban location of their practices. We
decline to ask about personal medical school debt because it is not
clear how this will influence pharmaceutical promotions in a conference
exhibit hall.
(Comment 13) One comment suggested adding questions about aspects
of promotional exhibit halls other than the booth representative.
(Response 13) This comment is outside the scope of the current
research. Researchers may want to explore additional questions in this
area for future studies.
(Comment 14) One comment noted that it would be helpful to track
whether advertisements outside of the exhibit hall encouraged providers
to visit certain booths within the exhibit halls.
(Response 14) This comment is outside the scope of the current
research. Researchers may want to explore additional questions in this
area for future studies.
(Comment 15) One comment recommended keeping the focus of Section 2
(recent conference behaviors) on general conference behaviors and
moving all product perception questions to Section 1.
(Response 15) Section 1 involves the specific manipulation of booth
representative credentials and the presence/absence of a disclosure.
Section 2 involves asking participants about a recent conference
experience. The advantage of this approach is that we can get more
specific information not influenced by retrospective guessing. The
opportunity to ask specific questions is one of the strengths of the
current study.
(Comment 16) One comment mentioned that the questions make use of
the term ``booth,'' while the Federal Register notice speaks to
``promotional booth'' and suggested that the survey questions use the
term ``promotional booth'' for clarity and consistency.
(Response 16) We have made this change.
(Comment 17) One comment mentioned that the questions use the term
``industry representative'' or ``drug representative'' and suggested
the survey employ the term ``industry representative'' exclusively to
ensure clarity and consistency.
(Response 17) We have revised the questionnaire to consistently use
the term ``industry representative.''
(Comment 18) One comment suggested we change the wording of
questions using the term ``exhibit hall'' to refer instead to
``promotional booths located in the exhibit hall,'' which is more
focused.
(Response 18) We have made this change.
(Comment 19) One comment suggested that for Questions 6-11, the
survey taker's responses can be influenced by other factors not
necessarily related to the content provided in the video, thus leading
to inconclusive results about the video presented.
(Response 19) Questions 6-11 refer to the experimental manipulation
in the video (see Response 6). Because we will have random assignment
to condition and the only differences in the videos will be the
credentials of the booth representative and the presence or absence of
a disclosure, we will be able to make causal claims if we see
differences in responses across conditions.
(Comment 20) One comment suggested that to eliminate the risk of
bias in the survey questions related to safety and efficacy, study
participants should be asked whether they think that the promoted drug
is safer and whether they think that the promoted drug is more
efficacious as compared to another drug.
(Response 20) This comment appears to refer to Questions 8 and 9.
These are
[[Page 37165]]
validated questions that have been used in previous studies (Ref. 10).
Development and validation of prescription drug risk, efficacy, and
benefit perception measures in the context of direct-to-consumer
prescription drug advertising. Research in Social and Administrative
Pharmacy). Moreover, the scale ranges from ``Strongly Agree'' to
``Strongly Disagree,'' so no bias is implied.
(Comment 21) One comment suggested that Questions 13 and 14 are
specific to one risk and that this risk may not pertain to all
situations, such as treatments for serious and life-threatening
conditions. The comment expressed confusion regarding how conclusions
from these questions can be applied to all drugs promoted at a
convention.
(Response 21) We specifically ask questions about this risk because
this is the risk that relates to the disclosure manipulation. These
questions will be used to determine if the presence of a disclosure
influences participants' responses to the relevant information in the
ad.
(Comment 22) One comment suggested that Questions 22 and 23 should
be reworded to define what part of the conference (poster session,
exhibit hall, oral sessions, etc.) the words ``conference sessions''
are referring to.
(Response 22) We have now specified ``oral and poster sessions'' in
these questions.
(Comment 23) One comment suggested that followup questions should
be added for participants that answer ``Yes'' to Question 24 as
follows:
What was the background of the person who made this presentation?
Answer Options: Scientific background, Business
background.
What part of the conference was this presentation presented at?
Answer Options: Symposia/Oral sessions, Workshops, Poster
sessions, Exhibit hall.
(Response 23) We considered adding these questions to the
questionnaire. However, after adapting the survey for a current and
post-COVID-19 world, these questions were ultimately not included so
that the information collection could stay within the proposed burden
estimate.
(Comment 24) One comment suggested that Question 30 should be
reworded so that it is specific to the particular types of materials
checked in Question 29.
(Response 24) We have removed Question 30 from the questionnaire
due to time constraints.
(Comment 25) One comment recommended the addition of a choice that
reads, ``met with the sales representative virtually,'' for Question
51, as this has been occurring more frequently during the COVID-19
pandemic.
(Response 25) This response option was added.
FDA estimates the burden of this collection of information as
follows:
Table 1--Estimated Annual Reporting Burden 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Number of responses per Total annual Average burden per response Total hours
respondents respondent respondents
--------------------------------------------------------------------------------------------------------------------------------------------------------
Screener...................................... 933 1 933 .08 (5 minutes)......................... 74.64
Pretest....................................... 25 1 25 .33 (20 minutes)........................ 8.25
Main test..................................... 368 1 368 .33 (20 minutes)........................ 121.44
---------------------------------------------------------------------------------------------------------
Total..................................... .............. .............. .............. ........................................ 204.33
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ There are no capital costs or operating and maintenance costs associated with this collection of information.
III. References
The following references marked with an asterisk (*) are on display
at the Dockets Management Staff (HFA-305), Food and Drug
Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852, 240-
402-7500) and are available for viewing by interested persons between 9
a.m. and 4 p.m., Monday through Friday; they also are available
electronically at https://www.regulations.gov. References without
asterisks are not on public display at https://www.regulations.gov
because they have copyright restriction. Some may be available at the
website address, if listed. References without asterisks are available
for viewing only at the Dockets Management Staff. FDA has verified the
website addresses, as of the date this document publishes in the
Federal Register, but websites are subject to change over time.
1. Mack, J. (2006, March). ``Effective Physician Marketing at
Medical Meeting Exhibits.'' Pharma Marketing News, 5(3).
2. * Industry Standard Report. (2014). ``Pharmaceutical Detailing:
In-Person vs. Electronic vs. Phone.'' Retrieved from https://www.isrreports.com/wp-content/uploads/2014/08/ISR-Pharmaceutical-Detailing-In-Person-vs.-Electronic-vs.-Phone-Preview-Aug2014.pdf.
3. * Steinman, M.A., G.M. Harper, M.M. Chren, et al. (2007, April).
``Characteristics and Impact of Drug Detailing for Gabapentin.''
PLoS Med, 4(4), e134. https://dx.doi.org/10.1371/journal.pmed.0040134.
4. * Adler, D., Manager Marketing Analytics, A. Sherman, Client
Services, and M. Walz. (2017). ``Medical Conference Presence: Is it
Worth it for your Brand?'' Retrieved from https://www.pharmavoice.com/article/2017-9-medical-conferences/.
5. * FDA. Warning letters and notice of violation letters to
pharmaceutical companies. Retrieved from https://www.fda.gov/drugs/enforcement-activities-fda/warning-letters-and-notice-violation-letters-pharmaceutical-companies.
6. Brock, T.C. (1965, June). ``Communicator-Recipient Similarity and
Decision Change.'' Journal of Personality & Social Psychology, 1,
650-654.
7. Braunsberger, K. and J.M. Munch (1998). ``Source Expertise Versus
Experience Effects in Hospital Advertising.'' Journal of Services
Marketing, 12(1), 23-38.
8. Siemens, J.C., S. Smith, D. Fisher, and T.D. Jensen (2008).
``Product Expertise Versus Professional Expertise: Congruency
Between an Endorser's Chosen Profession and the Endorsed Product.''
Journal of Targeting, Measurement and Analysis for Marketing, 16(3),
159-168.
9. Pechmann, C. (1992). ``Predicting When Two-Sided Ads Will Be More
Effective Than One-Sided Ads: The Role of Correlational and
Correspondent Inferences.'' Journal of Marketing Research, 29(4),
441-453.
10. Kelly, B.J., D.J. Rupert, K.J. Aikin, et al. (2021).
``Development and Validation of Prescription Drug Risk, Efficacy,
and Benefit Perception Measures in the Context of Direct-to-Consumer
Prescription Drug Advertising.'' Research in Social and
Administrative Pharmacy, 17(5), 942-955.
Dated: July 7, 2021.
Lauren K. Roth,
Acting Principal Associate Commissioner for Policy.
[FR Doc. 2021-14936 Filed 7-13-21; 8:45 am]
BILLING CODE 4164-01-P