Banner ad linking to a corporate-branded site hosting CHE opportunities
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If a pharma company creates an online DTC banner ad linking to a gated CHE site sponsored by the same company. Would the entire CHE site (beyond the gating) be subject to PAAB review, or just the gated page you are directed to from the banner ad.
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In general, accredited CHE materials are not considered advertising when the conditions are met per the Distinction between Advertising and other Activities and as such, they are also exempt from PAAB review under code section 1.5. Linking the CHE website to a branded DTC banner, will render the CHE to be promotional in its entirety, i.e. pre and post gate. Should it be forwarded to PAAB, the entire site will be requested for review. Please also see our Guidance on which HCP materials require PAAB review”.
As the CHE content was created without the advertising regulations in mind, the more realistic path forward is NOT to link it to advertising. I suggest rethinking usage of the the banner ad.
Let us know if you believe we've misinterpreted what you have in mind. -
@yin-man Sorry if I was not clear. The CHE is not linked from a branded DTC banner. The banner linking to the site is unbranded and consistent with the site itself; it only mentions CHE opportunities on the educational site and links to the educational site.
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Thank you for the clarification. We will set aside the banner ad for a moment and address the collection of accredited CHE on a gated section of a corporate sponsored website first. It is important that this method of distribution / dissemination of the CHE meets the accrediting body’s regulations (possibly including approval by the body). Also, if there is any content in addition to the accreditor-approved library of manufacturer-sponsored CHE on the website, that website likely requires PAAB review. At the very least, the website framework should be reviewed.
With regards to the non-product branded banner ad, when understood that it meets the accrediting body’s regulations (possibly including approval by the body), it would not require PAAB review if the website did not require review. If there was any content in addition to the accreditor-approved library of manufacturer-sponsored CHE on the website, then the banner would be assessed as part of our review of the website framework.
This sort of scenario is multi-factorial. If there are additional factors you’d like us to consider regarding this initiative, please submit an advisory opinion.
