If you want to comment on the issue of Direct-to-Consumer prescription
drug advertising, you may want to consider saying:
* While it is vital that consumers be empowered with information about
pharmaceuticals, DTC ads are about promotion, not education.
* Many DTC ads understate safety risks, which is likely to lead to
inappropriately increased consumer demand.
* Much of the public mistakenly believes DTC ads receive special clearance
from the FDA -- and that only the safest drugs can be advertised on
television -- leaving consumers vulnerable to and overly trusting of
DTC promotions.
* DTC ads generally fail to provide key information to consumers: success
rate for the drug, alternative treatments, how long the drug must be
used.
* Evidence shows that physicians are influenced by advertising to make
poor prescription decisions; consumers are similarly affected.
* DTC ads encourage consumers to demand brand-name products from doctors.
Evidence suggests doctors are influenced by these demands, and sometimes
prescribe requested medicines despite ambivalence about the choice of
treatment.
* DTC ads encourage to consumers to buy needlessly expensive products
instead of cheaper generics, burdening the overall health care system.
* Given the proliferation of DTC advertising, the widespread abuses,
and the paucity of evidence suggesting DTC ads contain significant educational
information or improve patient well-being, the FDA should be moving
the in direction of more rather than less regulation of DTC ads.
* The FDA should issue regulations specifically for DTC advertising,
to establish clear rules for what is and is not permitted.
* One important step would be pre-review by the FDA of ads; the current
system relies on self-restraint by drug manufacturers and a very inadequate
and underfunded system of FDA warning letters sent after offending advertisements
are aired or published.
* DTC advertisers should be required to run corrective ads after receiving
FDA warning letters
* Consumers should be empowered with useful information. This should
be provided by FDA on the Internet, in inserts included with pharmaceuticals,
and elsewhere. The information should be written in easy-to-understand
language, and include information on success rates, and comparative
efficacy and pricing data. This is how consumers' right to know should
be satisfied, not through promotional advertisements that are inevitably
slanted.
