On June 6, 2014, the US Food and Drug Administration (FDA) issued a draft guidance addressing the distribution of new risk information to health care providers (HCPs) and health care entities (HCEs). The draft guidance defines “new risk information” as “information that becomes available after a drug is marketed that rebuts or mitigates information about a risk already identified in the approved labeling or otherwise refines risk information in the approved labeling in a way that does not indicate great seriousness of the risk.” The draft guidance is not intended to address risk information that is newly identified, but that which was not available at the time FDA approved the labeling. Acknowledging the evolving nature of a drug’s safety profile, the draft guidance is aimed at helping sponsors better communicate “new risk information” in order to allow HCPs and HCEs make the best decision for each patient.
Through the guidance, FDA lays out criteria for determining the appropriate circumstances under which to distribute “new risk information” to HCPs and HCEs. FDA does not intend to object to the distribution of new risk information as long as the distribution is consistent with the criteria established in the draft guidance.
The criteria are broken into two categories, those governing the data source and those governing the distribution. Both criteria categories must be met in order for a drug company to distribute new risk information that rebuts, mitigates, or refines risk information in the approved labeling.
Data source criteria include the following:
- The study or analysis should meet accepted design and other methodologic standards and be sufficiently well-designed and informative;
- If the data rebuts a prior determination about a causal connection between the drug and an adverse event, the study or analysis should be at least as persuasive as the data it is rebutting;
- The conclusions should give appropriate weight and consideration to all relevant information in the safety database, including contrary or otherwise consistent findings; and
- The study or analysis should be published in an independent, peer-reviewed journal.
Distribution criteria include the following:
- The reprint or digital copy should be accompanied by a cover sheet that clearly and prominently discloses:
- The study design, critical findings, and significant methodology
- That the information is NOT consistent with certain risk information in the approved labeling
- That FDA has not reviewed the data; and
- Any financial interests or affiliations between the study author(s) and the drug company;
- The reprint or digital copy should be accompanied by the approved product labeling;
- The reprint or digital copy should be separate from any promotional material; and
- Any statements made by a drug company representative to a HCP or HCE concerning the reprint should be consistent with the content and the disclosure information.
Comments on the draft guidance should be submitted by August 20, 2014.