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.
703 - Regarding the PAAB Guidance document "Tips relating to inclusion of expert commentary in drug advertising", would the same rationale and requirements apply to patient testimonials?
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Similar to an expert commentary, a patient testimonial is basically a single person’s opinion. An individual’s opinion alone is not considered sufficient evidence to support product claims in advertising (PAAB Code section 3.1.3). As explained in the tips document, the caveat to this is if the individual’s opinion/patient testimonial is consistent with evidence or with consensus opinion from an independent, authoritative source that meets the standards of the PAAB Code. The supportive content must be presented prominently in close proximity to the individual’s opinion within the piece and the individual’s comment must meet the standards of the PAAB Code (e.g. must not be absolute, must not be disparaging, etc.).
