Can a signed letter from the Patient Support Program vendor, accompanied with a data table be used as data on file to support a message of length of time patients are on therapy i.e. retention?
Jennifer Carroll last edited by
As per the document Tips on Claims Relating to Patient Assistance Programs,:
“Observational data on retention could be considered if the program has a valid and reliable mechanism to monitor when prescriptions are filled. Sufficient information about the program must be provided to enable PAAB to make this assessment. The APS claim/data from a manufacturer’s patient support programs should be non-comparative (as it relates to the manufacturer’s product), it should reflect past study findings (i.e. formatted in the past-tense), and it should be structured so as to limit the findings to the support program. Study parameters such as the time period pertaining to the claim/data could be relegated to a footnote. Note that retention data will be required to be updated every 6 months as changes in the market place can impact retention.”