Claims Substantiation: Keep Marketing Bold and Compliant
Marketing wants bold statements. Regulators demand defensible evidence. Without a
system, you end up rewriting copy at the eleventh hour or—worse—launching claims
that cannot be defended later.
This playbook balances creativity with compliance. You will curate an evidence
library, run disciplined review checklists, manage expiry dates, and monitor
performance so every claim stays accurate throughout its lifecycle.
Why strong substantiation matters
- Regulatory trust: Health authorities expect promotional material to match
the label and be backed by sound evidence. Violations trigger warning letters
and corrective actions.
- Brand credibility: Physicians, payers, and patients rely on truthful claims.
One misstep damages reputation.
- Operational efficiency: A structured approach shrinks review cycles and
reduces rework.
- Strategic agility: With a ready library of vetted claims, marketing teams
can respond quickly to market opportunities.
Step 1: Build a shared evidence library
- Centralize clinical studies, health economics data, real-world evidence, and
internal analyses that support each claim.
- Tag entries by jurisdiction, indication, therapeutic area, claim type (efficacy,
safety, convenience), and label section.
- Record provenance, approval status, and links to source systems or publications.
- Store the library in a controlled platform with versioning, access control, and
search capabilities.
Step 2: Define claim taxonomies and templates
- Classify claims into core categories (label-based, comparative, patient support)
with clear criteria.
- Provide templates that outline required elements: claim statement, supporting
evidence references, market scope, intended channel, and expiry date.
- Ensure claims align with approved labeling; flag any requests needing
regulatory escalation.
Step 3: Implement role-based review checklists
- Design checklists for medical, regulatory, legal, and commercial reviewers.
- Require explicit references for every statement with page/figure citations.
- Include risk questions: Is the claim aligned with the label? Are comparators
fair-balanced? Are disclosures present?
- Capture decisions, comments, and approvals in one system to maintain an audit
trail.
Step 4: Manage claim lifecycle and expiry
- Assign review dates based on evidence maturity, competitor activity, and
regulatory changes.
- Automate reminders for upcoming reviews; escalate overdue claims to owners and
QA.
- Archive or update claims when labels change, new safety data emerges, or
supporting studies lose relevance.
- Track regional variations and ensure localized claims remain aligned with local
labels and regulations.
Step 5: Train teams and drive adoption
- Educate marketing and agencies on how to request claims, access the library,
and prepare evidence packets.
- Provide quick reference guides and office hours to resolve questions.
- Embed usage expectations in agency contracts and brand guidelines.
Metrics that prove success
- Claim creation and approval cycle times by channel.
- Percentage of claims with current evidence and on-time reviews.
- Rate of first-pass approvals versus iterations.
- Number of claims retired proactively versus reactively.
- Regulatory or medical review findings tied to insufficient substantiation.
45-day roadmap
evidence. Identify gaps.
metadata standards.
campaigns, and refine based on feedback.
reminders, measure cycle time improvements, and share metrics with
stakeholders.
Frequently asked questions
- Who approves claims? Typically medical affairs or regulatory affairs with
marketing input. Define roles clearly to avoid bottlenecks.
- How do we handle global versus local claims? Maintain a core global library
and extend with regional variants that reference local label differences and
evidence.
- What about digital channels? Apply the same substantiation rules. Capture
hashtags, banners, and landing pages as distinct claims when messaging differs.
- Can agencies access the library? Yes, with controlled permissions and NDA
coverage. Monitor usage and audit logs.
Sustain the win
Review the claim portfolio quarterly, refresh the library as new data emerges,
and rotate checklist owners so expertise spreads. Celebrate campaigns that pass
review on the first round to reinforce discipline. When claims are backed by
ready evidence, marketing stays bold—and compliant.