754: We want to develop an unbranded, ungated website that we plan to send to ASC. The content is about adherence and as such is appropriate for all audiences. Can we develop unbranded promotional tools, like banner ads on NEJM, that direct HCPs to this site?

  • The content and execution of this tool will impact the answer. In general, if the primary objective is to direct HCP to the tool to learn and implement, then the tool should be reviewed and approved by PAAB as it requires assessment for an HCP audience. If the objective is to inform HCP’s that a tool exists which they can direct consumers towards, then an assessment of the link would be required. PAAB would assess if the linked content was acceptable in the context of the message copy as the primary audience is HCPs.