ATTR-CM Quick Takes: Recognizing Indicators (002) - Extra Cardiac – Compliance Alert

Lower Risk

This HCP Educational video is within acceptable compliance thresholds.

Analysis of this 196s HCP Educational video identified 3 enforcement patterns, primarily Fair Balance. Patterns span Efficacy, Fair Balance — “Comparative Claims” identified at 7.6s, previously cited in NEXLIZET, COBENFY. Benefit-to-risk presentation ratio is 15.3:1.

Recommended action: Flag for next MLR cycle: Benefit-to-risk presentation balance requires attention. Ensure risk information receives comparable prominence, duration, and audio/visual treatment.

Video Timeline

Risk disclosure: 97.9s – 109.9s (12.1s of 196.3s total — 6.2% of ad)

Risk Window

0s49s98s147s196s

No visual distractions detected

Risk Window?

Patterns Detected (3)

Each pattern below is a known FDA enforcement concern, identified by matching this ad against 14 violation types from 34 FDA warning letters

Pattern	Dimension	Score	Evidence	CFR
Comparative Claims Claims suggesting superiority without adequate supporting data	Efficacy	91	1 clip	21 CFR 202.1(e)(5)	▶
FDA Concern: Advertisements cannot be false or misleading in any particular Previously cited: NEXLIZET, COBENFY
Dramatic Before/After Before/after visuals that may overstate treatment outcomes	Efficacy	91		21 CFR 202.1(e)(5)	▶
FDA Concern: Advertisements cannot be false or misleading in any particular Previously cited: TURALIO, TREMFYA
Benefit vs. Risk Time Imbalance Significantly more time spent on benefits than on risks	Fair Balance	55	1 metric	21 CFR 202.1(e)(3)(iii)	▶
FDA Concern: Risk and benefit information must be presented with equal prominence Previously cited: FABHALTA, Vyvgart Hytrulo (x2), Wegovy, Vonjo Benefit:Risk Ratio: 15.25:1

Compliance Alert: ATTR-CM Quick Takes: Recognizing Indicators (002) - Extra Cardiac

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