Risks in Direct-to-Patient Engagement

Direct-to-Patient (DTP) models are transforming how medications reach patients, moving beyond clinical research into commercial distribution. Originally developed to help rare disease trial participants avoid long travel to research sites, DTP has become a standard solution for improving patient access and convenience. Today, patients can receive small molecules, complex biologics, and even medical devices directly at home, making what was once exceptional now routine.

Despite the benefits, DTP introduces significant operational and regulatory challenges. Compliance is complex because different states have different rules for pharmacy shipments, and FDA promotion rules still apply to delivered medications. Privacy is another critical concern: each shipment involves sensitive health data protected under HIPAA and state-specific laws. Additionally, liability questions arise—who is responsible if shipments fail during transit, or if temperature-sensitive biologics are compromised?

Equity and safety are other key considerations. Companies must ensure patients in rural or underserved areas can access DTP services and maintain oversight to prevent fraud or improper inducement. Temperature-sensitive products require careful supply chain management, and transparency in patient communication is essential to build trust and minimize risk.

To navigate these challenges, organizations need strong governance and clear processes. SOPs should define responsibilities, vendors must be closely monitored, and privacy should be integrated into systems from the start. Early engagement with regulators helps align expectations, and proactive patient communication fosters confidence. DTP is here to stay, and implementing it responsibly can empower patients while reducing regulatory and operational risk.

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