Please advise if our representatives can email their HCPs (1:1) with an update on the COVID-19 situation and how our company is functioning at this time. There will be no product or promotion. The representative would offer the HCP a virtual appointment or call. A reply from the HCP would then allow representative to share PAAB approved materials.
Jennifer Carroll last edited by
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).