Promotional Intelligence, by Compliance Forward

PI: 11 (Part 2) Inside the FDA Layoffs

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 16:09:33 GMT

Virginia Foley "Industry Insider" and Jason Cober "Regulatory Authority" discuss the April 2025 Reductions in Force (RIF) at HHS, specifically at FDA. Hear a first hand account about how the Reductions in Force were executed on April 1, 2025.

PI: 11 (Part 1) Inside the FDA Layoffs

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 16:07:53 GMT

Virginia Foley "Industry Insider" and Jason Cober "Regulatory Authority" discuss the April 2025 Reductions in Force (RIF) at HHS, specifically at FDA. Learn about what is a RIF and why these were different.

PI: 09 Beyfortus & Tobi Podhaler Untitled Letters

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 16:06:04 GMT

In the newest episode, Virginia Foley and Jason Cober discuss the recent FDA-OPDP Untitled Letters issued for BEYFORTUS and TOBI PODHALER.

Unclear on how the FDA expects product Indications to be presented in promotional materials? What can patients and caregivers say about a product in a testimonial?
‪@complianceforward‬

PI: 08 A Journey in Time--Rx Drug Ads on TV

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 16:04:20 GMT

We are back... this time to talk about the history of how the Adequate Provision requirement is being fulfilled with DTC drug advertising on television.

The 1999 FDA guidance didn't permit DTC TV ads—yet it's being described today by FDA as a regulatory "loophole". 🧐

Spoiler: the first branded TV ad was actually in 1983, and the regulations' roots go much deeper.

Virginia Foley and Jason Cober from ‪@complianceforward‬ take a trip down memory lane and discuss what DTC Television ads looked like before 1999 and how we got to today with the recently added (2023) CCN regulations.

Whatever happens next, one thing’s for sure—policy decisions aren’t made in a vacuum, and understanding the history helps us see the bigger picture.

PI: 10 New Era of Enforcement w/special guest John Driscoll

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 16:01:32 GMT

In this latest episode of the Promotional Intelligence podcast, Virginia Foley and Jason Cober from ‪@complianceforward‬ welcome special guest John Driscoll, Founder of OPDP Resources. Get their take on this breakout year of FDA enforcement action following the HHS announcement from September 2025 announcing the "crackdown" on DTC Rx advertising

PI: 07 From Payor Guidance to PIE and Back w/ special guest Dara Katcher Levy

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 15:54:52 GMT

Virginia and Jason are joined by Dara Katcher Levy to discuss the FDA's recently revised Payor Guidance.

PI: 06 CFL Gone Wild - Vyepti Untitled Letter

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 15:52:22 GMT

Jason and Virginia from ‪@complianceforward‬ complete a rapid response review of the recent enforcement letter issued for violative promotion using CFL (consistent with FDA approved labeling) data to promote efficacy claims and also PRO (patient reported outcomes) data from post-hoc analyses. Listen and learn! Like what you hear, subscribe to the Promotional Intelligence podcast to stay up-to-date on all things related to Regulatory Ad Promo in pharma & biotech.

PI: 05 Why is FDA Calling Adequate Provision a "LOOPHOLE"?

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 15:50:18 GMT

The FDA's latest proposal targets what they refer to as the "adequate provision loophole" in advertising, pushing for full disclosure of risk information in TV and radio ads. What does this mean for the future of drug marketing?

Application of the final rule could result in a veritable ban on DTC broadcast advertising. Expect longer ads or a shift in advertising strategies, especially towards social media, as companies adapt to these changes. 📺➡️📱

Watch the latest episode @complianceforward

What are your thoughts on this potential shift? Discuss in the comments below.

PI: 04 What do we need to know about ELSA 4.0 - FDA's AI Tool

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 15:40:55 GMT

Virginia (Industry Insider) and Jason (Regulatory Authority) discuss the FDA's recent press release announcing ELSA 4.0 - what do we know about the Agency's use of AI and what remains unknown?

AI is transforming industries, and the FDA is no exception. With the recent announcement of ELSA 4.0, the FDA has taken a significant step forward in integrating AI into its review processes. But what does this mean for Industry? In this podcast, Jason Cober explores the implications of ELSA 4.0, its potential benefits, and what industry professionals need to know to navigate this evolving landscape.

*Understanding ELSA 4.0*

The May 6 Press Release from the FDA highlighted several key features of ELSA 4.0, including the consolidation of over 40 applications into a single system named HALO (Harmonized AI and Lifecycle Operations). This consolidation aims to streamline data processing and improve the efficiency of the review process. ELSA now includes functionalities such as custom agents, data visualization, voice-to-text dictation, and document generation. These enhancements are designed to support FDA staff in their day-to-day tasks, potentially speeding up review and approval timelines.

*The Importance of AI Integration in FDA Reviews*

The integration of AI tools like ELSA could significantly impact the FDA's operational efficiency. With the ability to query data and build workflows without manual document uploads, ELSA has the potential to reduce the overall workload on FDA reviewers. However, the success of this technology largely depends on its adoption across the agency. Understanding how frequently FDA staff are using ELSA is crucial for industry professionals looking to optimize their submissions and align with the FDA's new processes.

*What We Still Need to Learn About ELSA*

Despite the promising features of ELSA 4.0, there are still many unanswered questions. For example, we need clarity on the underlying large language model (LLM) that powers ELSA. Knowing which LLM is in use is vital for industry professionals as it impacts how submissions are processed and evaluated. Without this information, companies are left guessing how to format their submissions to align with the FDA's expectations.

*The Role of Communication in Navigating Regulatory Changes*

As the FDA continues to implement AI-driven solutions, maintaining open lines of communication with FDA reviewers is essential. Industry professionals are encouraged to engage with their reviewers, asking questions about how ELSA is being utilized and what specific features may help streamline their submission process. This proactive approach can provide valuable insights into the review process and ensure submissions are optimized for the current AI environment.

*Key Takeaways*

1. ELSA 4.0 is a significant advancement in the FDA's use of AI, with the potential to improve review efficiency.
2. Understanding which AI model powers ELSA is critical for optimizing submissions.
3. Open communication with FDA reviewers can provide insights into how to navigate the new AI landscape effectively.

PI: 12 ASA-3000 Untitled Letter - Pre-approval Promotion

Virginia Foley, Founder of Compliance Forward — Wed, 02 Sep 2026 15:27:41 GMT

Virginia and Jason from @complianceforward discuss the August 2026 Untitled Letter issued by OPDP for pre-approval promotion of ASA-3000 - an investigational product.

This letter includes several key violations and highlights the importance of ensuring medical communication regarding investigational products - especially those in the pre-approval phase - remains non-promotional.

PI: 03 - Photofrin Untitled Letter (June 22, 2026)

Virginia Foley, Founder of Compliance Forward — Tue, 07 Jul 2026 23:23:42 GMT

Virginia (Industry Insider) and Jason (Regulatory Authority) breakdown the details of the Photofrin Untitled Letter issued by OPDP on June 22, 2026.

PI: 02 (Part 2) - Oncology Time-to-Event Endpoints

Virginia Foley, Founder of Compliance Forward — Tue, 07 Jul 2026 23:14:20 GMT

In Part 2 of this episode Jason Cober (Regulatory Authority) and Virginia Foley (Industry Insider) continue the conversation and talk about the trend of FDA enforcement in oncology time-to-event data presentations in the recent bolus of letters, coming from both CDER and CBER.

PI: 02 (Part 1) - Oncology Time-to-Event Endpoints

Virginia Foley, Founder of Compliance Forward — Tue, 07 Jul 2026 23:12:17 GMT

Jason Cober (The Regulatory Authority) and Virginia Foley (The Industry Insider) from @complianceforward take a deep dive into the world of time-to-event endpoints as measured by single-arm trials. They dissect the FDA's position on development of these types of clinical trials and explain why the promotional enforcement letters are stacking up. Enjoy part 1 and stay tuned for part 2.

PI: 01 - SUCRAID Untitled Letter

Virginia Foley, Founder of Compliance Forward — Thu, 04 Jun 2026 22:00:00 GMT

In this episode, Jason and Virginia break down the recent enforcement letter regarding Sucraid, highlighting its misleading promotional materials. The FDA has flagged two emails targeting healthcare professionals for their claims about the product's indication and presentation of safety.

We dive into the details—what was wrong with the promotional emails? And what should be done differently to ensure compliance?

This conversation sheds light on the importance of accurate communication in healthcare. Let’s not forget: clarity in presenting risks is crucial for patient safety!

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