Acknowledging Caronia: FDA Takes The First Step To Rethinking Off-Label Policy

FDA has gotten past the denial phase and now is listening to ideas on how to balance the need to preserve the integrity of the regulatory process with evolving interpretations of the First Amendment as it applies to commercial speech. That is slow but important progress – but towards what goal?

They say the first step towards change is awareness of the need for change. If that is true, then FDA appears to be taking the first step towards changing policies regarding the regulation of off-label promotion.

Acknowledging the evolving understanding of First Amendment protections for commercial speech by pharmaceutical companies was a recurring theme during the 2014 Food & Drug Law Institute annual meeting. The April...

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