• Eleanor M Perfetto, John E Bailey, Kathleen R Gans-Brangs, Steven J Romano, Norman R Rosenthal, and Richard J Willke.
• Pfizer Inc., Washington, D.C., USA. eleanor.perfetto@pfizer.com
• Health Aff (Millwood). 2012 Oct 1; 31 (10): 2213-9.

AbstractThis article provides a perspective from the pharmaceutical industry on a hypothetical comparative effectiveness research case, highlighting tension between the reality of conducting comparative effectiveness research and the regulation of biopharmaceutical industry communication. Specifically, under current law and regulations, Aesculapion, the hypothetical maker of the fictional migraine headache drug Hemikrane, would have limited ability to communicate findings or to respond to inaccurate "what-if" scenario communications. Principles for communicating drug information could increase decision makers' access to information while making it easier for them to assess the quality and potential biases of different information sources. The article proposes two complementary approaches: formal Food and Drug Administration guidance clarifying how industry can participate meaningfully and proactively in the comparative effectiveness research discourse, possibly based on 1997 legislation governing communication of "health care economic information"; and stakeholder collaboration on development and adoption of voluntary "good communication principles."

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