CFL Guidance Trial and Error Think Tank: Meeting the Three Factor Test
Nada Glavan
Senior Director, Commercial Regulatory Affairs, Neurology Business Unit
Eisai US
Richard Lem
Associate Director, Regulatory Affairs – Advertising and Promotion
Bayer Healthcare
This industry think tank will examine advertising and promotional practices within the context of the FDA’s CFL Guidance and three- factor test. Join us as we analyze recent interpretations of
the guidance and stories of success and failure:
- Understanding what it means to promote product information from within the label
- Exploring the concept of “out-of-label” claims
- Understanding how the requirements of the CFL guidance interact with the NDA process
- Does the claim need to be in the label or simply consistent with the label?
- Examining off- label communications in relation to the CFL Guidance and First Amendment challenges
- Understanding what it means to promote product information from within the label
- Discussing the impact of these challenges in the Amarian and Novartis cases