Medication regulatory agencies (such as Health Canada,
the FDA, etc.) have no authority in deciding on how medicine is practiced. That
is the role of professional and licensing bodies. Thus, while a medication
may be “off label” as far as the medication regulatory agency is concerned,
that medication may be a useful part of accepted medical practice as far as
professional and licensing bodies are concerned.Therefore, medicines may be frequently
used in a medically appropriate manner, even if they are “off label”.
Fundamentally, the lack of a “label” for use does not
mean that the medicine is not appropriate for use in any particular medical
condition (that is a professional and licensing oversight decision). What
this means is that the medication has not received medicine regulator approval
for treatment of the condition in which the physician is using the medication,
frequently because the company making the
medication has not submitted for
regulatory approval.
There are many useful criticisms that can be made of this
state of affairs, not the least of which is the confusion that the concept of
“labeling” has created in the minds of the public and health providers alike. Another
criticism is the concern that the standard of proof for safety and efficacy
required by medicine regulatory agencies prior to the awarding of a “label” for
use may be less for those uses not labeled. Other criticisms may relate to
concerns that the public may be less protected from “off label” use than it is
from “on label” use. Some commentators point out however that all “over
the counter” medications and “health supplements” (including herbal remedies)
and all psychological treatments never receive regulatory approval – despite
their widespread use.
So what is the patient or the family to do in such a
confusing situation?
Just because a treatment is “off-label” does not mean
that it is not appropriate. If that were the case then many of our
medication treatments would be deemed inappropriate and all of our
psychological treatments would be deemed inappropriate.
First, is to understand what the tem “off label” use
means, and what it does not mean.Hopefully, the information in part one of this
post helps with that. Unlike what the mass media suggests, “off label” use
does NOT mean dangerous, ineffective or inappropriate use. So
gaining clarity and understanding is a good start.
Second, is to understand what questions you should ask
your health provider about ANY treatments that you are receiving. All
treatments should be based on best available evidence of effectiveness and
safety. This is called “evidence-based medicine”.
All treatments should be subjected to the same degree of
rigorous scientific scrutiny and judged by the same high standards. All
patients and their families have the right to know the evidence upon which any
treatment is based and it is the ethical duty of their health provider to
provide them with that information.
So, here are the questions to ask:
- Why
are you recommending this treatment?
- What
is the evidence (effectiveness and safety) supporting the use of this
treatment for people who are like me and who have the same diagnosis (or
problem) that I have?
- What
regulatory or professional bodies support the use of this treatment?
- What
are other treatments that could be used?
- What
is the evidence for those treatments? Is it stronger or weaker than
the evidence for the treatment you have recommended?
There are many other questions you should ask about your
treatments. Reading the evidence-based medicine information guide for patients and seeking
more information about medications at www.teenmentalhealth.org should
help with that.
~ Dr. Stan Kutcher
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