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  2. PAAB Q&A
  3. FYI post-approval change/preclearance exemption/what requires review/PAAB scope
  4. Guidance on which HCP materials require review
PAAB Notice
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.

Guidance on which HCP materials require review

Scheduled Pinned Locked Moved FYI post-approval change/preclearance exemption/what requires review/PAAB scope
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  • T Offline
    T Offline
    tk2022
    wrote on last edited by
    #1

    I understand there is a decision tree tool uploaded by PAAB titled "Guidance on which HCP materials require PAAB review."

    However the response to PAAB Q&A 763 appears to conflict with the tool.

    The tool allows for materials that discuss drug therapy or content relating to drug therapy to be PAAB exempt (if you follow the path to the end).
    However, the response in Q&A 763 states that disease info materials that mention treatment by name class or category are not PAAB exempt.

    Can you please clarify? The Decision Tree makes it seem that these materials are PAAB exempt but the Q&A question states otherwise.

    My understanding is the Decision Tree is for any HCP materials which would include unbranded materials. It would be great to see the decision tree updated.

    Jennifer CarrollJ 1 Reply Last reply
    0
    • T tk2022

      I understand there is a decision tree tool uploaded by PAAB titled "Guidance on which HCP materials require PAAB review."

      However the response to PAAB Q&A 763 appears to conflict with the tool.

      The tool allows for materials that discuss drug therapy or content relating to drug therapy to be PAAB exempt (if you follow the path to the end).
      However, the response in Q&A 763 states that disease info materials that mention treatment by name class or category are not PAAB exempt.

      Can you please clarify? The Decision Tree makes it seem that these materials are PAAB exempt but the Q&A question states otherwise.

      My understanding is the Decision Tree is for any HCP materials which would include unbranded materials. It would be great to see the decision tree updated.

      Jennifer CarrollJ Offline
      Jennifer CarrollJ Offline
      Jennifer Carroll
      wrote on last edited by
      #2

      Hey @tk2022

      Q&A #763 refers to just one scenario which could render a piece exempt. The tool outlines other factors/scenarios that may or may not render a piece exempt from PAAB pre-clearance.

      Can you please provide us with the flow you followed through the tool and the nature of the piece you’re thinking of (unbranded/branded, treatment/no treatment, company generated/independently generated, distribution, etc.)? This will help us better assess the question. (Note 6.6. in the document will be updated to 1.5D per the current code.)

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