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    • L

      Video with PAAB approved slide deck
      • llotter

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      Jennifer Carroll

      Hello @llotter
      No, the video is not considered exempt. If the review of the deck did not include the voiceover and/or there are any other additional features (e.g. animations, zoom, pop-ups, footnote presentation etc.), these could all impact the review. This video would require it’s own review.

    • U

      Patient profile "interactivity"
      • Username

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      Jennifer Carroll

      Hello @username

      It is possible to allow the doctor to choose aspects of the patient to build a patient case. However, variable elements which may be subject to quantification, would be required to have support within the piece. These are things like goal statements, comorbidities, concomitant therapy, consequences of the disease/condition, or observed outcomes. Also, undue emphasis (e.g. repetition, a common theme/trend, etc.) on any patient characteristic(s), would require product-specific support within the APS. This includes the “occupation” field if there appears to be a theme/trend related to this field.

      Each permutation with quantifiable claims would require a separate submission.

    • A

      Promotional claims in market research
      • andreworeilly

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      A

      Hi @jennifer-carroll!

      Thanks for your reply. Makes total sense. The IMC ethics code for Market Research is quite brief so I appreciate you explaining the practical application. Agree with your conclusion, especially regarding breadth of audience, in this example.

    • G

      Emailing Guidelines to HCPs
      • georgian21

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      Jennifer Carroll

      Good Morning @georgian21

      Rep emails are considered PAAB exempt when they are true one-to-one communications. If this is not truly a one-to-one communication (pre-prepared, sent to many etc.) it would not be considered exempt. (See Dissemination” in the document Clarification regarding digitization of APS: Helping healthcare product manufacturers plan for the evolving COVID-19 operational context)
      To address the various scenarios:

      This would be acceptable This would likely be acceptable upon confirmation from the Canadian medical body in the respective field (What constitutes current medical opinion) An assessment of the link and linked content would be made during the review process Link to specific sections would not be acceptable. Linking to the homepage of authoritative consensus guidelines may be considered
    • D

      New PAAB logo on APS we plan to retire
      • Donna

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      Jennifer Carroll

      Yes @Donna, that would be fine.

    • T

      Payer audience
      • tmcd

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      Jennifer Carroll

      @tmcd Please see response to PAAB Q&A 302.

    • Jennifer Carroll

      401 - Is there a PAAB mandate anywhere that states that the pharmaceutical companies corporate logo has to appear on all PAAB reviewed and approved APS materials? We have a situation there are high-priority approved APS materials requiring printing; however the corporate branding is changing and won’t be fully established for some time.
      • Jennifer Carroll

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      Jennifer Carroll

      Hi @NatBourre, the distinction is “company logo” versus “company name”. The code does not require a company logo. However, the company name is required on all pieces unless it contravenes other regulations, such as help-seeking messages. The distinction between “logo” and “name” was particularly relevant to the question as it featured concerns about displaying the corporate logo in the midst of a corporate branding change.

    • S

      COVID-19 Patient Support Program
      • SKW

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      Jennifer Carroll

      @SKW

      If independent third party content on COVID-19 is being provided to a patient through a branded patient support program, an assessment of the linkage should be performed to ensure the acceptability of the content within the context of the brand. This remains true even if being sent without the brand logo (i.e. they are being sent the content because they are part of the branded patient support program). PAAB would do an assessment of the linkage to the content which could be done through an opinion file and would be subject to the four day turn around time.

    • S

      Covid-19 Question
      • SKW

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      Jennifer Carroll

      Hello @SKW
      In answer to your question, please note that the same email sent individually to several doctors would not be considered a 1:1 message. The message described above could be considered exempt if it meets the limitations of a corporate message with no product mention (e.g. identifying or alluding to a product name, class, category). See code section 1.5E. We strongly urge that the email copy goes through the manufacturer’s internal compliance channels. If there are any doubts that the message is truly corporate and does not allude to products, it can be submitted to PAAB for an opinion (4 day turnaround).

    • Jennifer Carroll

      744 - Change in Product Ownership - if Company A divests Product X to Company B, can Company B continue to use promotional material for Product X that was previously approved by PAAB for Company A during the DIN transfer, or only post-DIN transfer? If so, can it be used until the renewal date?
      • Jennifer Carroll

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    • J

      There are a lot of clinical trials underway on Medical Cannabis. If some of these trials are successful and Medical Cannabis companies can start making claims will they be required to submit their APS's to PAAB?
      • Jeff Kent

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      J

      @Jennifer-Carroll said in There are a lot of clinical trials underway on Medical Cannabis. If some of these trials are successful and Medical Cannabis companies can start making claims will they be required to submit their APS's to PAAB?:

      Medical cannabis is a healthcare product. Healthcare professional (HCP) advertising for medical cannabis therefore falls within the scope of the PAAB Code of Advertising Acceptance. Currently, medical cannabis advertising may not contain claims, even when directed to healthcare professionals. Advertising materials that do not contain claims are exempt from preclearance for any product category (excluding opioids).
      However, specific medical cannabis products that are granted a form of Terms of Market Authorization (TMA) based on evidence relating to particular therapeutic uses will presumably be permitted to make claims in HCP advertising. Of course, those materials would exceed the exemption criteria outlined in the PAAB code and would not be exempt from preclearance.

      Thanks Jennifer - this is very informative. We will share this with our customers.

    • Jennifer Carroll

      732 - Is this "Ask PAAB" still active? We have submitted queries 4-weeks ago and did not see any responses? Could you please provide an update?
      • Jennifer Carroll

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    • Jennifer Carroll

      731 - Is the PAAB logo required to appear on HCP advertising or patient information approved by PAAB.
      • Jennifer Carroll

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    • Jennifer Carroll

      730 - Hi Patrick, I have a question related to providing PAAB training. I remember few years ago you came to our company and you provided training. There have been many changes since then and I was wondering if you are still providing similar training. What is the cost associated with this type of activity?
      • Jennifer Carroll

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    • Jennifer Carroll

      728 - Hi Patrick - I've read the 2019 Client Survey report on the PAAB website. Is there a plan to disseminate this more broadly, and what actions is the PAAB taking with regards to any of the specific survey results? Thank you.
      • Jennifer Carroll

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    • Jennifer Carroll

      717 - How can I access archival copies of the PAAB Code? I am looking for the version relevant to 1996. Many thanks.
      • Jennifer Carroll

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    • Jennifer Carroll

      710 - For Help-Seeking Announcements, the Distinction Between Advertising and Other Activities states "there is no implication that a drug is the sole treatment available". Does this mean no implication for a single brand within the context of available drug treatments, or no implication for drug treatment over non-drug treatment?
      • Jennifer Carroll

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    • Jennifer Carroll

      700 - Can we present two different brands, (which are two different therapeutic areas) in one APS (i.e. in a LB) as long as the indication and balancing info is presented for both brands?
      • Jennifer Carroll

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    • Jennifer Carroll

      693 - Is a non-medical device associated with a drug be recognized as a therapeutic product regardless of whether the ad in question contains information about the drug itself in a direct to consumer standpoint?
      • Jennifer Carroll

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    • Jennifer Carroll

      692 - In DTC would non-medical devices (i.e. Breezhaler/Respimat/Ellipta) be associated with their drugs immediately? As such be limited to the name, price and quantity in terms of messaging or would there be leeway to talk about device features in a comparative standpoint or would that be against the code?
      • Jennifer Carroll

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