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Review

Controversies in off-label prescriptions in dermatology: the


perspective of the patient, the physician, and the
pharmaceutical companies
ß a, MD, PhD
Katlein Franc , and Sergio Litewka, MD

Department of Dermatology & Cutaneous Abstract


Surgery, Institute for Bioethics & Health The term “off-label drug use” involves the prescription of medications for unapproved
Policy, University of Miami Miller School of
indications or in unapproved dosage, dosage form, or route of administration. Off-label
Medicine, Miami, FL, USA
medications are common in the management of dermatologic diseases. In the recent
Correspondence years, new indications for botulinum toxin, biologics, spironolactone, topical calcineurin,
Katlein Francßa, MD, PhD and topical vitamin D analogues emerged, and these drugs are being used off-label to treat
Department of Dermatology & Cutaneous a variety of conditions. The high cost and long time required for the approval discourage
Surgery
pharmaceutical companies from developing studies and pursuing the approval by
Institute for Bioethics & Health Policy
regulatory agencies. Patients and physicians may have a different perspective regarding
University of Miami Miller School of
Medicine the off-label use of medications. The ethical discussion is based on the different opinions
1400 NW 10th Avenue concerning the need for informed consent by the patient and how this could be applicable
Suite 912 in the clinical practice.
Miami, FL 33136
USA
E-mail: k.franca@med.miami.edu

Funding: None.
Conflicts of interest: None.

doi: 10.1111/ijd.14222

strategies for managing risks.4 The process of drug develop-


Introduction
ment, from initial development through final market approval,
The term “off-label drug use” involves the prescription of medi- requires 10 years on average.2 Since the FDA does not regu-
cations for unapproved indications or in unapproved dosage, late the practice of medicine, an off-label prescription is gener-
dosage form, or route of administration. Government drug regu- ally legal unless it violates ethical guidelines. Off-label
latory agencies are responsible for confirming the efficacy and prescriptions in dermatology empower and give options to
safety of medications after performing rigorous evaluations of physicians allowing them to innovate within the scope of their
preclinical and clinical studies.1 The US Food and Drug Admin- clinical practice and may be particularly useful for patients not
istration (FDA) is the regulatory agency for all food and drugs responding to standard treatments.5 On the other hand, the
sold in the United States. This agency is also responsible for inappropriate use of off-label drugs raises significant concerns
the oversight of many other products such as cosmetics, dietary about safety. To limit liability, physicians are advised to pre-
supplements, vaccines, and biologics, among others.2 The Cen- scribe medications that have a well-accepted therapeutic value
ter for Drug Evaluation and Research (CDER) is the main FDA in the medical community, proven efficacy from results of clini-
division responsible for the approval of drugs. The CDER is cal trials, and only for indications that they believe are in the
responsible for evaluating over-the-counter and prescription best interest of the patient.6,7
drugs, including biological therapeutics and generic drugs
before they can be marketed in the United States and ensures
Off-label prescriptions: clinical research vs.
their safety and efficacy and that the health benefits outweigh
medical treatment
the known risks.3 The drug approval process takes place within
a structured framework that includes three main steps: analysis When a new drug is approved and becomes available on the
of the target condition or illnesses and available treatments, market, all the information about it is based on pre-marketing
assessment of benefits and risks from clinical data, and studies. Preclinical studies start with the development of the
1

ª 2018 The International Society of Dermatology International Journal of Dermatology 2018


2 Review Controversies in off-label prescriptions in dermatology Francß a and Litewka

molecule, followed by experimental studies in animals to identify for the treatment of diabetes but prescribed for weight loss,
its effects and toxicity. If no unacceptable toxic effects are caused fatal valvular heart disease in some patients and led to
observed, the first clinical trials in humans are conducted. a controversial discussion and changes in the regulatory sys-
These are named phase I, II, and III studies. They investigate tem. A law that aimed at strengthening of the safety of medici-
aspects of the pharmacokinetics, toxicity, safety, and efficacy in nes and healthcare products and a related decree regarding
humans.8 All clinical trials should follow ethical guidelines, “Temporary Recommendations for Use” filled part of the gap,
requiring the approval of the institutional ethics committee and providing France with a regulatory process for temporarily
written informed consent from the participants of the study.9 supervising the off-label prescribing drugs. Emmerich et al.
Drawing a clear line of demarcation between drugs used in explained, “The intention of the French law and the TRU decree
research vs. medical treatment can be challenging. The general is to open a relatively long observation window to assess the
idea is that when a product is used to treat a patient, it is con- benefits and risks of a marketed drug for an unlicensed indica-
sidered therapy and when it is used to conduct a clinical trial, it tion and to collect scientific information to ensure its safe use. A
is medical research. However, it is not always clear when an TRU is granted for a maximum of 3 years, a window that should
off-label medication is being used for experimental research or permit the manufacturer to expand its marketing authorization
not.5 A common mistake belief among patients is that when a through the usual procedures.”12 Pediatric patients in France
physician prescribes an off-label medication, he is conducting are one of the groups most exposed to off-label medications. A
experimental research on the patient. Riley et al. suggest that study involving 2,313 pediatric patients showed that 1960 were
the most basic test for whether an off-label use qualifies as exposed to ≥1 prescribed drug. Among children with prescrip-
experimental research is to focus on the physician’s motivations tions, 37.6% were exposed to ≥1 off-label prescription and 6.7%
and goals in prescribing that medication for off-label use. The to ≥1 unlicensed drug. Off-label prescribing involved an unap-
National Commission for the Protection of Human Subjects of proved indication in 56.4% of cases, a lower dosage (26.5%) or
Biomedical and Behavioral Research explains: “The distinction higher dosage (19.5%) than specified, age not labeled (7.2%),
between research and practice is blurred partly because both incorrect route of administration (3.5%), and contraindication
often occur together (as in research designed to evaluate a (0.3%). This study highlighted the high prevalence of off-label
therapy) and partly because notable departures from standard prescriptions among pediatric patients in that country despite
practice are often called ‘experimental’ when the terms ‘experi- the innumerous initiatives toward the promotion of rational use
mental’ and ‘research’ are not carefully defined.”6,10 of medications in children.13 Picard et al. performed a study to
access off-label prescribing in dermatology in France. The
authors found that 86% of the prescriptions were labeled and
International perspective: regulations and
14% were off-label. The most frequent indications for off-label
frequency of off-label prescriptions in
prescriptions were inflammatory and hypersensitivity dermato-
different countries
sis. Topical corticosteroids and methotrexate were the most pre-
Off-label prescriptions occur in all medical specialties, but they scribed off-label medications. The authors also found that 70%
may be more common in areas of medicine in which the patient of these off-label prescriptions were not based on strong data
population is less likely to participate in clinical trials, for exam- from evidence-based medicine.14 In Portugal, in 2014, an
ple psychiatric, pediatric, geriatric, oncology, and pregnant administrative guideline from the Portuguese Health’s Direction
patients, or in rapidly evolving medical specialties like dermatol- (DGS) recommended a written informed consent for all off-label
ogy, considering the need to repurpose existing therapies for prescriptions. Portuguese health authorities consider it neces-
cutaneous conditions, given the broad variety of pathophysio- sary to inform the patient on the particular therapy, its potential
logic processes affecting the skin and long time to approve new risks and benefits, and the reasons that led the physician to
drugs.5,7 It is estimated that 21% of the prescriptions in the Uni- prescribe an off-label medication and not an approved one. All
ted States are off-label. Radley et al. analyzed nationally repre- information should be comprehensibly noted in the patient’s
sentative data from the 2001 IMS Health National Disease and records to ensure protection for the patient and the physician.
Therapeutic Index (NDTI) to define prescribing patterns by diag- The challenge remains on adjusting this demand with the elec-
nosis for 160 commonly prescribed drugs and found that off- tronic medical records and with mechanisms like the Por-
label use was most common among cardiac medications (46%, tuguese Health Data Platform, which is a Personal Electronic
excluding antihyperlipidemic and antihypertensive agents) and Health record, a National Electronic Mechanism to share data
anticonvulsants (46%), whereas gabapentin (83%) and from federated systems, and a basis for innovation in eHealth in
amitriptyline hydrochloride (81%) had the greatest proportion of Portugal.15,16 Just like in other countries, the use of off-label
off-label use among specific medications. The authors found medications among the pediatric population is a common prac-
that 73% of off-label mentions had little or no scientific sup- tice. Silva et al. analyzed 1,011 prescriptions in neonatology of
port.11 In France, in 2012, a scandal involving the prescription 84 active substances, made in 218 hospital admissions. The
of Mediator (benfluorex) – a fenfluramine derivative approved authors found that in 42.9% of the cases, medicines were used

International Journal of Dermatology 2018 ª 2018 The International Society of Dermatology


Francß a and Litewka Controversies in off-label prescriptions in dermatology Review 3

according to the Summary of Product Characteristics informa- publishes “Therapeutic Alerts” on pharmacovigilance in the
tion; 27.9% of drugs were approved for neonatal period but official journal. The goal is to alert following adverse reactions
used in an off-label manner; off-label drugs for neonates were from the off-label use of drugs. These public measures to
used in 10.1%, whereas those with undetermined approval state restrict off-label prescriptions are more common in the control
and contraindicated were used 6.0 and 8.7% of the cases, of the incentives and the dissemination of information to the
respectively, and unlicensed prescriptions accounted for 4.4% medical community.8,22 Just like in the US, the regulatory agen-
of total.17 Another study including patients aged from 4 days to cies cannot restrict off-label prescriptions beyond educational
18 years assisted in a Portuguese pediatric emergency unit campaigns and have no jurisdiction on the practice of medicine.
found that of the 724 medicines prescribed, 32.2% were off- Brazilian legislation on this subject still lacks greater investiga-
label. At least one drug was used off-label in 28.1% of the stud- tion and subsequent measures. In Brazil, off-label prescription
ied population, corresponding to 46.1% of the 427 children that in pediatrics is also a frequent practice. A study involving pedi-
received prescriptions. “Alteration in dosage” was the common- atric patients from southern Brazil showed that the frequency of
est reason for off-label prescribing (28.2%).18 Among the many off-label medications prescribed was 31.7%. The highest preva-
dermatology diseases, the off-label prescriptions in pediatric lence was antihistamines and antiasthmatics (32.3% and
psoriasis have been widely discussed by dermatologists in Por- 31.5%, respectively), and the main type of off-label prescription
tugal. Psoriasis is a chronic inflammatory systemic disease that was dose (38.8%), followed by age range (31.5%), and the fre-
causes important physical and physiological burden. One-third quency of administration (29.3%). Regarding the dosage, over-
of the cases have their onset during the pediatric age, although dose was more frequent (93.3%) than underdose (6.7%).23
some of them may not be diagnosed until the patient reaches
adulthood. The correct diagnosis and treatment during child-
Off-label prescriptions in dermatology
hood can delay and prevent comorbidities. Most of the treat-
ments prescribed to these patients are off-label and based on Off-label medications are common in the management of der-
therapies only approved for adults. Reivas et al. highlighted, matologic diseases. New therapeutic approaches for common
“Because children are not just ‘small adults’, specific guidelines or rare dermatosis are continually being released, as well as
for the diagnosis, management, and treatment of psoriasis are new indications for old drugs. Dermatologists are the medical
of extreme importance.”19 professionals qualified to diagnose and treat more than 3,000
In Germany, off-label prescriptions can cause financial different diseases. These multitudes of diagnosis, the need for
responsibilities for the physician. Insurance companies tend to therapeutic options, and the long time required by the regulatory
accept off-label prescriptions only in cases of severe, potentially agencies to approve new medications make off-label prescrip-
life-threatening diseases. Seidenschnur et al. explain that to tions for dermatologic diseases so common. These experiences
avoid reimbursement claims following the prescription of off- of off-label use, if analyzed within the context of a carefully
label medications, physicians in Germany should – on a case- designed methodology, may provide scientific data that can
by-case basis – file an application for cost coverage with the influence or even improve further concepts of therapy. However,
competent health insurance before treatment initiation. These the blurred boundaries between what constitutes medical treat-
authors performed a chart review for cost coverage requests ment, that is, focused on the patient, or research (aimed to gen-
submitted by two outpatient clinics at a university-affiliated der- erate knowledge) represent a fertile ground for ethical and legal
matology department between 2010 and 2012 and found that in controversies. A study that analyzed data from the 1990–1997
the majority of cases (56.8% of applications were approved dur- National Ambulatory Medical Care Survey, performed by the
ing the first round), health insurers in Germany have agreed to National Center for Health Statistics, assessed medications pre-
reimburse the costs of proposed off-label therapies.20 scribed at office visits for dermatologic conditions. The authors
In Brazil, the regulatory agency responsible for the approval found that the range of off-label prescribing varied from 17 to
of medications is ANVISA (Age ^ncia Nacional de Vigila ^ncia 73%. The conditions most frequently treated with off-label pre-
ria). In general terms, ANVISA follows the same proce-
Sanita scriptions were acne rosacea (73%) and actinic keratosis
dures of FDA to approve a drug.21 However, the approval of a (52%), whereas those with the fewest off-label prescriptions
medication in Brazil can take longer since some medications were atopic dermatitis (17%) and psoriasis (16%). The use of
are first approved in the USA and only later the registration for off-label prescriptions by dermatologists in the diseases studied
approval is requested in Brazil. It is also possible that a medica- ranged from 7 to 73% whereas the range for non-dermatolo-
tion could receive the approval by another regulatory agency gists was 18 to 96%.24
based only on preliminary studies or incomplete studies, and
this is not acceptable by ANVISA.22 Brazilian healthcare institu- Botulinum toxin
tions have created pharmacology committees to evaluate the Botulinum toxin is a neurotoxin produced by the bacteria
~o Paulo, the Health
off-label use of drugs. In the State of Sa Clostridium Botulinum. This substance has been widely used in
Surveillance Center acts as a pharmacovigilance institution and the dermatological practice. It acts by blocking the nerve signals

ª 2018 The International Society of Dermatology International Journal of Dermatology 2018


4 Review Controversies in off-label prescriptions in dermatology Francß a and Litewka

that contract muscles resulting in temporary paralysis of the Spironolactone


muscles.25 It is approved by the FDA for facial esthetic treat- Spironolactone is a potassium-sparing diuretic that has been
ments (temporary reduction of crow’s feet, glabellar lines, and used since 1954 for the treatment of hyperaldosteronism.33
moderate to severe forehead lines) and primary axillary hyper- Other indications include heart failure, primary hyperaldostero-
hidrosis.26 Botulinum toxin has been used off-label for the treat- nism, cirrhosis of the liver accompanied by edema and ascites,
ment of many other dermatological conditions with variable and nephrotic syndrome. The anti-androgenic activity of
results.27 A review study published in the Journal of the Euro- spironolactone discovered in 1969 led to the future uses in der-
pean Academy of Dermatology showed growing evidence sup- matology. Nowadays spironolactone is used in dermatology, off-
porting the use of botulinum toxin in non-cosmetic label, to manage androgen-dependent conditions like adult
dermatological disorders such as pruritic dermatosis (pom- female acne, female pattern hair loss, hidradenitis suppurativa,
pholyx, idiopathic pruritus, lichen planus), acantholytic disorders and hirsutism.7,34 This medication is considered a useful tool in
(Hailey-Hailey disease, Darier0 s disease), inflammatory der- the dermatologic treatment armamentarium; however, further
matosis (hidradenitis suppurativa, flexural psoriasis), scarring, studies are necessary to establish the safety, efficacy, and new
fissures and ulceration (anal fissures, Raynaud0 s disease and indications for the treatment of dermatologic diseases.34
ulcers), and painful disorders such as vulvodynia and cutaneous
leiomyomas.28 The treatment of keloids and hypertrophic scars, Topical calcineurin inhibitors
alopecia, facial erythema and flushing, oily skin, Raynaud phe- Topical calcineurin inhibitors act by inhibiting synthesis of proin-
nomenon, chromhidrosis and bromhidrosis, and postherpetic flammatory cytokines. The only FDA approved indication is for
neuralgia with botulinum toxin are also under investigation.29 In the treatment of atopic dermatitis in patients 2 years old or
psychodermatology, botulinum toxin has been used for the com- older. It can be used as an alternative therapy to corticosteroids
plementary treatment of depression with positive results.30 This without the side effects commonly associated with the use of
potent drug is being used for several off-label indications of steroids. Topical calcineurin inhibitors have been investigated
interest for dermatologists. However, further clinical trials are for the off-label treatment of allergic contact dermatitis, psoria-
still needed to better understand the efficacy and safety of sis, lichen planus, vitiligo, rosacea, and seborrheic dermatitis.
these new indications and to standardize dose protocols.29 Although it only received regulatory approval for one indication,
this medication has shown promise in the off-label treatment of
Biologics other skin conditions.35
Biologics or biologic drugs are a protein-based drug derived
from living cells cultured in a laboratory. Biologics have been Topical vitamin D analogues
used in medicine for more than 100 years, but in the 21st Topical vitamin D analogues are approved by the FDA for the
century, new agents had a remarkable impact on the fields treatment of psoriasis but are also used off-label in the treat-
of dermatology, rheumatology, and gastroenterology. These ment of a variety of cutaneous disorders despite a lack of scien-
drugs target specific parts of the immune system and are tific evidence of efficacy. A systematic review involving 165
different from traditional treatments that affect the entire articles showed a moderate to strong recommendation for the
immune system.31 Biologic drugs have revolutionized the use of topical vitamin D analogues in combination with corticos-
treatment of patients with psoriasis. The biologic agents teroids and phototherapy in vitiligo and as monotherapy for
approved by the Food and Drug Administration for psoriasis ichthyoses, morphea, pityriasis alba, prurigo nodularis, and
and psoriatic arthritis include adalimumab, etanercept, inflix- polymorphous light eruption. It may be ineffective in the treat-
imab, ustekinumab, and secukinumab. There are several ment of actinic keratosis, seborrheic keratosis, lichen planus,
reports of off-label uses of these drugs for vasculitis such as seborrheic dermatitis, alopecia areata, chemotherapy-induced
polyarteritis nodosa, giant cell arteritis, granulomatosis with alopecia, and hypertrophic scars.36
polyangiitis, and Behcet disease, for eczema such as atopic
dermatitis and dyshidrotic eczema, and for inflammatory
Ethical discussion: patient, physician, and
conditions such as hidradenitis suppurativa, pityriasis rubra
industry perspectives
pilaris, lichen planus, graft-versus-host disease, erythema
annulare centrifugum, toxic epidermal necrolysis, acne The patient perspective
vulgaris, SAPHO (synovitis, acne, pustulosis, hyperostosis, Patients who are receiving off-label medications are not always
and osteitis) syndrome, alopecia areata, aphthous stomatitis, informed that they are a part of an experimental treatment.
primary amyloidosis, pruritus, keloid, wound healing, and Some off-label uses can be beneficial, mainly when therapeutic
pityriasis lichenoides chronica.32 Biologics may be regarded options are restricted and when the patient is facing an orphan
as a tool for the treatment of several dermatologic condi- disease where sometimes it can be the only available treat-
tions, although new clinical trials are needed to better ment.1,37 However, in order to be morally acceptable, off-label
assess their efficacy and safety. indications should be supported by well-formulated hypotheses

International Journal of Dermatology 2018 ª 2018 The International Society of Dermatology


Francß a and Litewka Controversies in off-label prescriptions in dermatology Review 5

and not merely by curiosity or baseless experimentation. Even therapeutic options based on the latest scientific evidence,
considering the uncertainty of innovative therapeutic options, although there is lack of evaluation of efficacy and safety of
the lack of an adequate study design might expose the patients these drugs.1 The ethical controversy lies on whether the physi-
to disproportionate risks. cian should disclose to the patient that he is prescribing an off-
Another topic to be considered is the patient’s right to be label drug or not. Wittich et al. explained that there are two
informed about his participation that is, eventually, an experi- arguments used by those who are against the disclosure. The
mental one. The prescription of off-label medications without full first one that “disclosure may unduly frighten patients” and sec-
disclosure by the physician raises many complex ethical and ond that “the extensive burden placed on physicians to con-
legal concerns.38 stantly review and communicate medication risk and benefit
Wilkes and Johns propose that the doctrine of informed con- information may divert attention away from other more important
sent should be rigorously applied to require doctors to disclose patient care issues.”5 Meadows and Hollowell argued that “the
to the patients when they are prescribing a drug off-label. These doctor’s decision to inform the patient of the ‘off-label’ status of
authors argue, “The same process of the informed consent the prescription is not relevant to the physician’s standard of
required before enrolling a patient in a research study should care for an informed consent case, and the doctor’s duty is to
be applied when a drug is being prescribed off-label as each practice medicine and treat his patient, not inform the patient of
such prescription is just like a mini research study.” This would the FDA’s non-medically related labeling. Therefore, doctors
be a way of respecting the patient’s autonomy and encouraging should not be branded with the additional duty of disclosing
them to share in decision making in situations of medical uncer- non-pertinent information, such as the FDA’s medically irrele-
tainty.39 Shared decision making is one the most important vant distinction, to their patients.”44 The majority of dermatolo-
aspects of the contemporaneous medical practice and requires gists prescribe off-label medications without informing their
that both the physician and patient share information and work patients that the drug was not approved for that indication. This
together to decide on the best treatment plan. Clearly, withhold- can be considered an unethical practice that violates patients’
ing the intent to prescribe an off-label drug fails to honor this right to information. Considering that physicians are legally
approach to the patient-physician relationship.40 bound to inform patients of risks and the fact that there is a lack
In the context of off-label prescriptions, from a moral stand- of research for off-label medications, this practice should be
point, it must be considered that “a valid, yet ignorant consent considered a risk to the patient, and it could be argued that the
is enough permission for therapy but not for experimentation.”41 physician who withholds this information is violating the ethical
Two other issues generate ethical tensions: therapeutic mis- duty to secure the patient’s informed consent and autonomy.40
conceptions and the possibility of undisclosed conflicts of The presence of possible undisclosed conflicts of interest by
interests. the physician adds another layer of complexity that must be
Therapeutic misconception occurs when individuals mistak- taken in consideration. Conflict of interest, by definition is a “set
enly believe that the aim of the treatment is to directly benefit of circumstances that creates a risk that the professional judg-
them, while, in fact, they are subjects in an experimental ment or actions regarding a primary interest will be unduly influ-
protocol.42 enced by a secondary interest.”45
The use of off-label prescription is particularly challenging For the physician, the “primary interest” is the patient, and for
since is not totally experimental (although the treatment out- the researcher, it might be the generation of knowledge. These
comes may be published as if it were research and, eventually, competing interests are intangible, therefore difficult to assess.
these studies may be submitted to the regulatory agency for However, financial conflicts of interest are a more concrete
approval) but may be presented to the patient as some sort of possibility. Is the physician experimenting with different doses
“innovative therapy.” or indications based on previous clinical experiences? Or is he
acting as an agent of the industry, carrying out a protocol that
The physician perspective is being tested in different sites by different medical providers?
Off-label prescriptions are considered legal, and physicians If the latter is the case, then it should be disclosed to the
have the freedom to prescribe any approved drug for any other patient and informed consent must be sought.
indication, regardless of the fact that the indication is not
approved by regulatory agencies.43 Physicians tend to prescribe The pharmaceutical company perspective
off-label drugs when the standard treatments are non-existent Upon the discovery and development of a drug, it may be found
or fail. Some drugs take time to be approved by regulatory that this drug could be useful for the treatment of different dis-
agencies. While the drug is going through the approval process, eases. However, pharmaceutical companies usually select few
a new indication can be discovered by an independent scientist. or the most important indications to develop further research.1
Even before the approval, high impact factor journals already The cost of the process of getting a drug approved by a regula-
publish scientific evidence about a new use of a particular drug. tory agency is high, and there is an increase in the number of
Physicians have the option and freedom to use these new patients and time required to complete the clinical trials.37

ª 2018 The International Society of Dermatology International Journal of Dermatology 2018


6 Review Controversies in off-label prescriptions in dermatology Francß a and Litewka

These are decisive factors on the number of indications that the 6 Riley JB Jr, Basilius PA. Physicians’ liability for off-label
industry will select for further evaluation. The same challenging prescriptions. Nephrol News Issues 2007; 21: 43–44, 46–47.
7 Adler BL, Friedman AJ. Repurposing of drugs for dermatologic
process is faced when the pharmaceutical company wants to
applications: five key medications. J Drugs Dermatol 2014; 13:
get approval for new uses of old medications. Gupta et al. 1413–1416.
explain “From a business point of view, to seek supplemental 8 Lima Carvalho M. Challenges on off label medicine use. Rev
approval for new uses late in a drug’s patent life is not very Paul Pediatr 2016; 34: 1–2. https://doi.org/doi: 10.1016/j.rppede.
enticing for pharmaceutical companies. The developmental cost 2015.12.007.
9 Khamar B. Off-label use of medicines: medical research and
of new uses of an old drug might exceed the benefit of regula-
medical practice. Indian J Ophthalmol 2007; 55: 411–412.
tory approval.”1 These are discouraging factors to pharmaceuti- 10 HHS.gov. The Belmont Report. 2018. https://www.hhs.gov/ohrp/
cal companies to conduct well-controlled clinical studies.46 Still, regulations-and-policy/belmont-report/read-the-belmont-report/
off-label medications sell worth many billion dollars resulting in index.html.
huge revenue.1 11 Radley DC, Finkelstein SN, Stafford RS. Off-label
prescribing among office-based physicians. Arch Intern Med
2006; 166: 1021–1026. https://doi.org/10.1001/archinte.166.9.
Conclusion 1021.
12 Emmerich J, Dumarcet N, Lorence A. France’s new framework
In recent years, new indications for botulinum toxin, biologics, for regulating off-label drug use. N Engl J Med 2012; 367:
spironolactone, topical calcineurin, and topical vitamin D ana- 1279–1281. https://doi.org/10.1056/NEJMp1208347.
logues emerged, and these drugs are being used off-label to 13 Palmaro A, Bissuel R, Renaud N, et al. Off-label prescribing in
pediatric outpatients. Pediatrics 2015; 135: 49–58. https://doi.
treat a variety of conditions. Off-label prescriptions can be bene-
org/10.1542/peds.2014-0764.
ficial to patients, allowing them to receive new therapeutic 14 Picard D, Carvalho P, Bonnavia C, et al. [Assessment off-label
options. However, the safety and efficacy of these drugs are prescribing in dermatology]. Ann Dermatol Venereol 2003; 130:
not confirmed by the regulatory agencies, and patients may be 507–510.
exposed to unrestricted experimentation and to an ineffective or 15 Barbosa C, Matos M. Prescricßa ~o off-label, direito a
 informacßa
~o,
consentimento informado e processo clinico eletro nico no direito
risky medication. The high cost and long time required for
portugue ^s. Cadernos Ibero Americanos de Direito Sanitario
approval discourage pharmaceutical companies from developing 2016; 5.
studies and pursuing the approval by regulatory agencies. 16 EPSA. The Portuguese Health Data Platform (PDS). 2017.
Patients and physicians may have a different perspective https://www.epsa-projects.eu/index.php?title=The_Portuguese_
regarding the off-label use of medications. The ethical discus- Health_Data_Platform_(PDS).
17 Silva J, Flor-de-Lima F, Soares H, et al. Off-label and
sion is based on the different opinions concerning the need for
unlicensed drug use in neonatology: reality in a Portuguese
informed consent by the patient and how this could be applica- University Hospital. Acta Med Port 2015; 28: 297–306.
ble in the clinical practice. While there is no consensus on this 18 Ribeiro M, Jorge A, Macedo AF. Off-label drug prescribing in a
subject, physicians are advised to prescribe medications that Portuguese paediatric emergency unit. Int J Clin Pharm 2013;
have a well-accepted therapeutic value in the medical commu- 35: 30–36. https://doi.org/10.1007/s11096-012-9699-y.
19 Relvas M, Torres T. Pediatric psoriasis. Am J Clin Dermatol
nity and only for indications that they believe are in the best
2017; 18: 797–811. https://doi.org/10.1007/s40257-017-0294-9.
interest of the patient. 20 Seidenschnur KEK, Dressler C, Weller K, et al. Off-label
prescriptions and decisions on reimbursement requests in
Germany – a retrospective analysis. J Dtsch Dermatol Ges
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