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The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.
  • Announcements regarding our community

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    Jennifer CarrollJ
    Good morning, @Manufacturer @Agency PAAB will be performing an upgrade to the eFiles system tonight, July 29th. We will be shutting the eFiles system down from 5pm-midnight to perform the upgrade. Please note that users will not have access to eFiles during this time. We’re sorry for any inconvenience that this causes. Thank you PAAB
  • A place to talk about whatever you want

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    Jennifer CarrollJ
    Hello @adelaidebaker As a general principle, the clinical decision to prescribe or switch should be made based on clinical considerations. Patient preference can be a part of a patient profile but should not be positioned as the reason to prescribe or switch. Patient preference can be presented as a consideration, without drawing conclusions about clinical actions. With respect to the specific case presented in the question, the copy in the guidelines and the APS would have to be assessed at the time of submission. We’d caution that “broadly defined” may be problematic and that drawing inference around patient choice such as “difficulty remembering to take pills and therefore might prefer injections” would require statistically significant evidence from a published high quality source.
  • Got a question? Ask away!

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    Jennifer CarrollJ
    Hey @mhouzer The difference between the Standard 4-day initial review of RMTs and submitting as an ARO-4 is that the subsequent revision turnaround time will be an expedited 2-days rather than the standard 3-days. If you anticipate needing a few rounds of back and forth, this can be a good option to get to your final letter more quickly.
  • Blog posts from individual members

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    Jennifer CarrollJ
    Good Afternoon @Manufacturer and @Agency It's crazy to say but we're now just past halfway through 2025! The PAAB Quarterly Tag and CEI Reports have been updated to contain data for Q2. See the Tag report here and the CEI report here. The Forum Quarterly Review for Q2 has also been posted here. If there's more you'd like to know in Q3, let us know in the comments below. Have a wonderful rest of the summer. Thank you PAAB
  • Have questions about how to use the forum, set up your account, functionality etc.? Ask them here and we'll help you out.

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    D
    Lets start with a quick registration video.
  • Do you have questions about particular sections of the PAAB code? Do you have insights on how sections of the code be improved? Do you want to share insights about how related standards are addressed in other jurisdictions? Post here.

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    M
    Hi! In reviewing this flowchart under the question “Is there discussion of drug therapy or content relating to drug therapy?”, would an APS that uses the word “medication” or "treatment" without referring to any specific medication be considered a “Yes” or a “No” for that question?
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    Jennifer CarrollJ
    Hey @dmauri Great question. As long as the study publication does not contain information suggesting dosing practices inconsistent with Canadian labelling, the manufacturer’s Medical/Regulatory Affairs department can confirm that the dosing in the jurisdiction where the study was conducted is the same as it is in Canada. When it comes to “SoC”, per 1.7 of the Guidance on Real-World Evidence/Data, remember that pooled comparisons are not acceptable which would render the second half of the question moot. However, if you are referring to SoC in a single-arm study (per Advisory: RWE Single-Arm Studies of Previously Treated Patients), we would look to ensure that the overwhelming majority of patients were on a product available in Canada/indicated in the same population in Canada. Regarding "SoC", please note the guidance's remarks on representing the marketplace versus exclusions by design. An opinion can be a great mechanism to get specific guidance on an individual study as it allows for assessment of the study design, therapeutic area, and indicated product(s).
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    Hello! Would it be possible to include a link to an unbranded PAAB-exempt APS (with official PAAB exemption) from a gated, unbranded disease-state website that is undergoing full PAAB review? Thank you.