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140 - If we place an ad in an HCP-focused journal, and provide a link to an HCP-focused website (either typed in or scanned using a 2-D scan code), can we assume that the audience has been sufficiently vetted as HCPs and provide branded drug information to them? This would be in lieu of asking for licence numbers or other means of identification.
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For prescription products and for drugs indicated to treat/cure Schedule A diseases, a gate of some sort is required to pose a true barrier restricting consumers from having access to the site. The relevant legislative authority is Section C.01.044 of the FDR and Section 3 of the FDA. The assumption in your question is only valid if the website is not searchable. In other words, the website could only be accessible to those who use the scan code or type that specific URL into the search field. Please call if you have any questions.
