Medical Affairs / Industry

How to Build a Medical Dossier That Withstands Regulatory Objections

A well-built medical or scientific dossier isn't just another document from a product launch: it's the asset from which the sales team presentation, the medical information Q&A, and much of the training material are derived. When it fails, the failure propagates to everything built on top of it. And it fails, almost always, for the same reason: it was written starting from the message the team wanted to convey, instead of being built from the available scientific evidence.

The right starting point is classifying the evidence by its level of confidence before writing a single line of messaging. The GRADE approach, already adopted by more than 100 organizations worldwide, explicitly distinguishes the quality of the evidence (high, moderate, low, very low) from the strength of the recommendation derived from it [1]. A message supported by a systematic review of randomized controlled trials shouldn't be presented with the same rhetorical weight as one supported only by case series or expert opinion [2].

A second critical point is traceability. Every clinical claim in the dossier must be traceable back to the original citation, with verification that the source actually says what the document claims it says. This is the first line of defense against a medical-legal review committee or a regulatory authority requesting documented support.

A third point, equally decisive, is updating. Scientific evidence isn't static, and a dossier that isn't revised when new evidence appears — or when local regulations require it — loses defensibility over time, even if it was flawless at the time it was written.

In Colombia, promotional and non-promotional content aimed at healthcare professionals must also align with the product's sanitary registration conditions, as established by current regulations on drug information and advertising [3]. A dossier that deviates from those conditions — for example, by suggesting unapproved indications — isn't just a reputational risk: it's a direct legal risk.

Building a defensible dossier takes time, but building it well once avoids rewriting the same scientific story — and correcting the same mistakes — in every piece of material derived from it.

References

  1. Guyatt GH, Oxman AD, Kunz R, Vist GE, Falck-Ytter Y, Schünemann HJ; GRADE Working Group. What is "quality of evidence" and why is it important to clinicians? BMJ. 2008 May 3;336(7651):995-8. doi: 10.1136/bmj.39490.551019.BE. PMID: 18456631; PMCID: PMC2364804.
  2. Petrisor BA, Keating J, Schemitsch E. Grading the evidence: levels of evidence and grades of recommendation. Injury. 2006;37(4):321-327.
  3. Instituto Nacional de Vigilancia de Medicamentos y Alimentos (INVIMA). Resolución 1896 de 2023, por la cual se regula la información no publicitaria, promoción, publicidad y comercialización de medicamentos y productos fitoterapéuticos. Bogotá: INVIMA; 2023. Available at: https://www.invima.gov.co/productos-vigilados/medicamentos-y-productos-biologicos/control-de-publicidad

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