The Value of the Black Box Warning in Dermatology

July 2015 | Volume 14 | Issue 7 | Editorials | 660 | Copyright © July 2015


Laura Winterfield MD MPH,a Ruth Ann Vleugels MD MPH,b and Kelly K. Park MD MSLa

aDivision of Dermatology, Loyola University Stritch School of Medicine, Maywood, IL
bDepartment of Dermatology, Brigham and Women's Hospital, Boston, MA

potentially pose greater risks than TCIs, particularly in light of decades of data which suggest that in transplant patients, oral calcineurin inhibitors are safer than oral systemic corticosteroids. 35
The tumor necrosis factor-alpha (TNF-α) inhibitors are biologic agents (eg, infliximab, etanercept, and adalimumab) that are increasingly used for the treatment of psoriasis and other dermatologic diseases. A boxed warning was added to the entire class because of a potential malignancy risk based on AERS lymphoma reports in children and adolescents.37 A recent meta-analysis of 63 randomized controlled trials and nearly 30,000 patients with rheumatoid arthritis, however, revealed no significant association between anti-TNF-α therapy and an increased risk of malignancy compared to other disease-modifying anti-rheumatic drugs or placebo.38 After years of conflicting data leading up to this study, this new information may influence prescribing practices unless dermatologists rely only on the package insert given that despite this new data, the black box warning on anti-TNF-α agents remains.
Regardless of the black box warning’s effect on legal liability, its intended purpose is to minimize severe adverse reactions in patients. Effective communication of new warnings to prescribers from both the FDA and manufacturers is the pivotal point in making the black box warning a successful risk management tool. The best strategy for disseminating a new black box warning is not known. Studies have shown that “Dear doctor” letters alone may have little impact on prescribing habits. These letters may be much more effective depending on their wording and whether they are accompanied by additional strategies such as media publicity.27 The FDA is interested in improving its overall approach to this problem, and has made changes in recent years to improve physician and patient awareness of new drug information and labeling changes.39
Furthermore, adherence to boxed warnings is voluntary with no system of monitoring to guide use of drugs with such warnings. Ambulatory electronic health records with computerized order entry and prescribing alerts related to boxed warnings do not improve clinicians’ overall adherence to boxed warnings, although do improve adherence in specific clinically important subcategories.40 In a large study in outpatient practices, 0.7% of prescriptions (n=324,548) violated an aspect of a warning, such as a drug interaction, inappropriate patient selection, or inappropriate monitoring. This was observed to be more common in patients over 75 years old and in those with multiple prescriptions. Despite this, fewer than 1% of these events resulted in an AE.41

Future of the Boxed Warning

Greater transparency is needed in the administration and clinical application of the boxed warning. This was illustrated in the clinical case presented here using becaplermin. Many questions remain regarding black box warnings. For example, how well does the current system work? How do dermatologists learn about boxed warnings? How does the knowledge of a boxed warning change dermatology practice? Do dermatologists feel compelled to counsel patients more extensively before prescribing a drug with a boxed warning? Do dermatologists avoid prescribing these drugs altogether and choose alternative treatments to avoid the extra time needed for counseling and/or monitoring, or even to avoid potential liability? What is the magnitude of some of these unintentional effects of the boxed warning? What if there is no other effective alternative treatment available? Further research is needed to identify which methods of communication have the greatest impact on dermatologists’ awareness of new boxed warnings as well as changes to warning data, thereby ultimately impacting patient safety.
In the context of prescribers’ schedules, variable learning methods and practice styles, including use of electronic medical records and prescribing software, we would expect the “most effective” communication strategy to be a dynamic combination of multiple simultaneous and staggered outreach efforts. The ideal combination of modalities is likely to change over time, requiring frequent reevaluation and adjustment to maintain efficacy.

DISCLOSURE

The authors have no conflicts of interest to declare.

REFERENCES

  1. Embil JM, Papp K, Sibbald G, et al. Recombinant human platelet-derived growth factor-BB (becaplermin) for healing chronic lower extremity diabetic ulcers: an open-label clinical evaluation of efficacy. Wound Repair Regen. 2000;8:162-8.
  2. Regranex® (becaplermin) [package insert]. Raritan, NJ: Ortho-McNeil, Division of Ortho-McNeil-Janssen; 2012 September.
  3. Update of Safety Review: Follow-up to the March 27, 2008, Communication about the Ongoing Safety Review of Regranex (becaplermin). (Accessed April 22, 2015, at http://www.fda.gov/Drugs/DrugSafety/PostmarketDrugSafetyInformationforPatientsandProviders/ DrugSafetyInformationforHeathcareProfessionals/ ucm072148.htm.)
  4. Ziyadeh N, Fife D, Walker AM, Wilkinson GS, Seeger JD. A matched cohort study of the risk of cancer in users of becaplermin. Adv Skin Wound Care. 2011;24:31-9.
  5. Chow I, Lemos EV, Einarson TR. Management and prevention of diabetic foot ulcers and infections: a health economic review. Pharmacoeconomics. 2008;26:1019-35.
  6. Ahmad SR. Adverse drug event monitoring at the Food and Drug Administration. J Gen Intern Med. 2003;18:57-60.
  7. Wood AJ. Thrombotic thrombocytopenic purpura and clopidogrel--a need for new approaches to drug safety. N Engl J Med. 2000;342:1824-6.
  8. rankford DM. Food Allergy and the Health Care Financing Administration: A Story of Rage. Widener Law Symposium J 1995; 1(1): 160-265.
  9. Beach JE, Faich GA, Bormel FG, Sasinowski FJ. Black box warnings in prescription drug labeling: results of a survey of 206 drugs. Food Drug Law J. 1998;53:403-11.
  10. Code of Federal Regulations Title 21--Food and Drugs. Revised as of April 1, 2014. (Accessed April 22, 2015, at http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=201.57.)