Sharing an unbranded patient resource
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Hello,
We would like PAAB’s guidance on the acceptability of a resource that a company would like to share at a conference booth. The conference is organized by a patient association, and this is a booth for patients on therapies in a certain therapeutic area. Our company is only including unbranded disease awareness information at the booth. The company originally developed a doctor discussion guide to give to patients on one of the company’s therapies in a particular therapeutic area (the company has multiple products in this therapeutic area). The document is unbranded with respect to product but includes the company name at the bottom of the document. The document is a ‘fill in the black’ document that is intended to be used for conversations with the patient’s prescribing HCP and it includes prompts to complete based on your experience (e.g., my current treatment experience is _______, here’s what is going well with my treatment _______, here is what could be improved about my treatment ________). Would this be acceptable to share with members of the patient association at a booth? -
Hey @hrj2021
As the piece is being handed out in a consumer space, it would be required to meet the consumer regulations requirements (Distinction Between Advertising and Other Activities). Since the handout appears to have been developed/reviewed as a product specific HCP-patient interaction tool, there may be an inherent link to the brand. We would suggest that this piece be submitted for a DTC review to ensure there is no brand mention, no link to a brand, and it meets the consumer requirements. It would also be pertinent to disclose the nature and other copy at the booth as links may make distribution of the piece unacceptable.
