he U.S. Food and Drug Administration (FDA) approves labeling claims of drug efficacy based on substantial evidence of clinical
benefit demonstrated in adequate and well-controlled investigations. Patient-reported outcomes (PROs) may support marketing
claims of clinical benefit, either alone or with other study endpoints. Health-related quality of life (HRQL) is a PRO that compre-
hensively measures patients’ reported health status. We present an overview of why HRQL-based efficacy claims have not to
date been accepted by the FDA for inclusion in anticancer product labels. Persistent challenges to allowance of such claims
include shortcomings in randomization and blinding of clinical trials, missing data, statistical multiplicity, and unclear intrinsic
meaning of selected HRQL findings.
J Natl Cancer Inst Monogr 2007;37: 27 – 30