Unauthorized Use of Content on this Site: 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 correspondence—are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content, or using it for model training or any related purposes, is strictly prohibited without the express prior written consent of PAAB. This includes, but is not limited to, the use of such materials in automated systems, machine learning models, or artificial intelligence applications.
293 - A pharmaceutical company has provided an unrestricted educational grant for the development of a disease-focused patient website. Can sales reps distribute postcards promoting the website (site name, disease focus, URL)?
-
From your question, it would appear that the piece is intended to be non-promotional. Assuming this to be the case, it is important to consider that distribution factors can render non-promotional content to be subject to the advertising regulations. As a general rule of thumb, if you want something to stay non-promotional, don't add promotional elements (e.g. promotional cards, drug reps...etc). Having said this, drug reps may distribute a postcard promoting this type of website to HCPs, but this would render the website subject to PAAB review (i.e. we'd review the card and the website). Note that the card should be non-branded if the site is non-branded. Also note that drug reps should not distribute content directly to patients.
