We believe that direct-to-consumer (DTC) advertising can be an important and helpful way to inform patients about diseases that may be relevant to them and about therapeutic options they may want to discuss with their physicians.
Our company has a long-standing policy of voluntarily submitting new U.S.-based DTC advertising campaigns to the FDA for its review and comment before running them. Under our DTC policies and practices, the information provided in our DTC advertising must:
- Contain appropriate product benefit and risk information
- Be appropriately balanced, consistent with FDA regulations, and use appropriate “taste and tone”
- Be approved by our company’s Promotion Review Team, a governing body consisting of a team of reviewers (including the job owner, an attorney, a physician, a representative from the Office of Promotion and Advertising Review, and a product scientific specialist) who ensure that promotional material is clinically and scientifically accurate, compliant with applicable laws and regulations, and compliant with company policy
We try to help consumers achieve better health outcomes by delivering accurate, relevant and understandable information on disease prevention, identification and potential treatment. To remain true to this goal, we adhere to the letter and spirit of U.S. Food and Drug Administration (FDA) regulations and guidelines governing DTC promotion, meet or exceed all Pharmaceutical Research and Manufacturers of America (PhRMA) guidelines on DTC advertising, and follow a comprehensive set of internal policies and practices when engaging in DTC advertising within the U.S.
We adhere to updated 2019 PhRMA guidelines that “all DTC television advertising that identifies a medicine by name should include direction as to where patients can find information about the cost of the medicine, such as a company-developed website, including the list price and average, estimated, or typical patient out-of-pocket costs, or other context about the potential cost of the medicine.” In addition, we include information on our U.S. Patient Assistance Program in all new U.S.-based DTC print and television advertisements for eligible products.
We inform and educate health care professionals about our products before we advertise them to consumers. We implement comprehensive programs to educate physicians and other prescribers about a new product for an appropriate period of time before starting product-specific DTC broadcast advertising in the U.S.
These principles and our practices are reflected in the PhRMA Guiding Principles on Direct-to-Consumer Advertisements about Prescription Medicines.