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Guidance on Code Application

66 Topics 115 Posts
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.

Subcategories

  • As we develop the draft RWE document, we wanted to create a space to share your questions and for you to ask additional questions.

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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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    Guidance on Patient Reported Outcomes

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    Jennifer CarrollJ
    Hi tk2022 Please see our more recent “Guidance on Real World Evidence/Data” for criteria and direction on the presentation of RWE in advertising to health care professionals. Please also see our "Guidance on the use of the Attention Icon" regarding unblinded data.
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    Advisory on Exclusivity Claims for Indications

    extneral advisory indication
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    Jennifer CarrollJ
    Hey @boram The level of fair balance will be dependent on the exclusivity claim and any additional copy required to support it. For the exclusivity claims discussed in the above document, highest level fair balance would likely be required as these are indication comparisons. See Question 1 in Guidance on Fair Balance Level Selection and Placement
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    Guidance Regarding Duration of Clinical Trials Used as Reference Support in Advertising

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    Jennifer CarrollJ
    Hi @alee The full TMA of both Drugs A and B along with original study would be required to assess the extension study. As an example, PAAB would need to assess the TMA of drug B to determine the parameters for the 1 year restriction—Does the 1 year restriction also relate to safety or is it only that the clinical trials were one year in length? Etc. The consideration for acceptability of the extension is dependent on the pertinent information. Given the nature of the required assessment, it would be advisable to consider the PAAB’s written opinion service (refer to the fee schedule on the PAAB website).
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    Guidance on the Presentation of Burdens of Disease in Advertising

    external guidance document disease info disease consequences disease burden
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    Jennifer CarrollJ
    Hey @kshulist The guidance does apply in this scenario. In addition to the considerations identified in your question, section 4.2 of the guidance relating to emphasis is also applicable. There should be no emphasis on burdens upon which the product has not demonstrated an effect and it should be part of a balanced presentation that includes burdens upon which the product has demonstrated an effect. Clear and prominent disclosure as per section 5.2 of the guidance will be required and this may include clarification of the indication even if it has already been included elsewhere. As a reminder, PAAB will be starting to review under the new guidance starting February 19th.
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    Guidance on When the Attention Icon is Required and Its Presentation

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    PAAB Exempt - Coverage/Reimbursement APS

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    Jennifer CarrollJ
    Hello @au3010 We would need to see the whole piece to make an assessment. We suggest submitting for an exemption request.
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    Advise on a symptom tracker app; does this need PAAB review?

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    Jennifer CarrollJ
    Happy Friday @iainb A symptom tracker that relates to a disease and not medication AE’s or medication outcomes, which contains no branding elements, could be considered exempt if there was no mention of treatment. If the tool speaks to treatment (even in an unbranded context) it would be subject to review. PAAB can provide an opinion if the piece is exempt. If you’ll want to proceed to approval if the piece is not considered exempt, please indicate this in the submission letter.
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    Part 3 of the PM in HCP directed pieces

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    @Jennifer-Carroll Yes, it will be positioned in the context of patient counselling, as there is no other information of proper use of device in the PM (other than part 3)
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    Clinical vs. Non-clinical claims

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    Jennifer CarrollJ
    Hey @mhe The answer is nuanced and context driven. While dosing has clinical relevance for appropriate use of the product, the convenience of once daily dosing does not necessarily translate into a clinical outcome such as adherence, safety, and/or efficacy. As such, a claim of “convenient once-daily dosing” would not require a disclaimer of “Clinical significance unknown” but it would not be permissible to present it in a context that suggests unsubstantiated significance.
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    Guidance on Risk Management Tools (September 2016)

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    @admin We note that modifications to RMTs require PAAB resubmission. Would this still be the case for a product logo or legalese update that does not alter any of the other content in the RMT? If PAAB resubmission is required, is there a way for a reduced fee to be applied (we note that updated legalese or logos are not part of the criteria for "Minor Update" reviews).
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    Advisory on the Use of Open Text Fields in APS

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    Jennifer CarrollJ
    Hey @laraholmes It’s unclear what “in this respect” is referring to. “Open text fields” are “blank” by definition as the rep determines the copy. The restrictions for open-text fields are that the manufacturer has confirmed the reps are trained to limit open-text to transactional element with no therapeutic, product or service/tool being mentioned (see full advisory above). It may be beneficial to set up a clarification call so that we can better understand your question. Please reach out to admin to set up a call with me.
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    Pre-planned extension studies

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    Jennifer CarrollJ
    Afternoon @keoca No that would not qualify. Specific timepoints must be clearly indicated as pre-planned.
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    Advisory on Small Space Ads

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    Advisory on Fair Balance Headings

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    Tips for Document Names and Descriptions for External Use

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    Advisory on APS Breakpoints and QR Code Links

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    Tips for Pre-NOC Corporate/Editorial Communications

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    Advisory regarding use of RAMQ in APS (April 2016)

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    Jennifer CarrollJ
    Hello @jen_antibody Great question. To clarify, the request from RAMQ is to ensure that the coverage criteria are always clear and complete, so as not to suggest the indication is the coverage criteria (except where this is indeed the case). The document states: Coverage claims must be accompanied by reimbursement criteria (if applicable to the indications promoted in the piece). This means, that not all criteria are required in the piece. The discrete criteria which are not for the indicated population (i.e. off-label criteria), CAN be removed from the coverage criteria. All formulary claims, across Canada, for discrete off-label use would need to be removed, this is not exclusive to RAMQ. If there are additional indications for the product, which RAMQ does not cover, the formulary presentation/claim should be clearly limited to the indications with RAMQ coverage. A statement similar to “For information on availability of formulary coverage in Quebec, please visit link” would still allude to RAMQ and be subject to the RAMQ request. However, to reiterate, the RAMQ request does not preclude the removal of off-label discrete coverage.