280 - Is including the names of Rx products on sales rep business cards and email signatures allowed ? Or are these considered APS or potentially DTC advertising . Thank you
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It appears that there is a chance that these cards will fall into the hands of consumers. We must therefore consider consumer regulations. The name of the drug alone would not exceed consumer regulations (provided the drug is not a narcotic or a controlled drug as consumer promotion of such products is completely prohibited). However, inclusion of anything which would allude to the therapeutic use of the listed drug (e.g. a drug rep title such as "Neuroscience Specialty Mood Representative") would exceed consumer restrictions for prescription products and for products used for the treatment of a schedule A disease. It is advisable to limit distribution to HCPs if including anything beyond the company name/address, the drug rep name & contact info, and a generic title such as "Product Representative". Should distribution be limited to HCPs as they contained specific drug rep types, PAAB would review these as corporate pieces with product mention. All cards across the company's product offerings may be submitted as a single piece. For each product we'd ensure the implied therapeutic classification is accurate and on-label. Note that inclusion of product claims would require fair balance.
