Medical Information
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Hi there,
I had a question in regards to Medical Information websites. Medical information falls under the unsolicited request for information in the code, however is there a way of notifying HCPs of a medical information website so that they have the correct contact information for the medical information department? For example, would field staff be allowed to be able to leave behind something that displays the medical information website URL? What would the regulation around this be?
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Hello @justineeve
It is possible to have a medical information website and to have the link or access to this site distributed by sales reps. If the message is promoting a service by the company and is being distributed by the sales rep, it should be reviewed by PAAB under Code section 7.4. During this review, we will look to ensure that there is no content or messages that could jeopardize the intent and execution of the medical information website remaining “non-advertising” per the Health Canada document, Distinction Between Advertising and Other Activities document. For example, a post card that encouraged HCPs to reach out to medical information for off-label information, would not be acceptable. Q&A 176 may also be a relevance.
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@jennifer-carroll Hi Jennifer, thank you for the prompt reply! Would this also apply to MSLs in the field? Would the piece still need to go through PAAB review if it just stated "X Medical Information" and then the URL?
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Hello @justineeve
Health Canada does not distinguish between titles applied to the employee. The role that they play and the actions taken are what should be considered. If the MSL is distributing service awareness tools/pieces proactively, they would likely fall under the scope of advertising and should be reviewed. However, if the piece is limited to the particular text in the question, and X=company name, there should be nothing to review regardless of whether it is distributed by a drug rep or MSL. The content in that particular execution would be exempt.
If the piece would provide information about the service, particularly with regards to access to information relating to drug therapy, the piece would likely require review. If you are unsure for any particular piece, feel free to submit an opinion for our assessment (PAAB Policy and Procedure for Exemption Requests).
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@jennifer-carroll Thank you! Are you able to point me to the location within the code that highlights this exemption?
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Hey @justineeve
Please see code section 1.5E.
