Visual connection between DTCI and unbranded HCP-facing DSE
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I'm wondering if it would be considered compliant to use the same creative concept (visuals/look/feel) in a disease state awareness campaign in the DTC space as in the HCP space. For added context, the DTCI campaign will likely include a broad and balanced discussion of treatment options and a CTA to talk to your doctor; it will go through ASC review. The HCP campaign will be disease state education only with no mention of treatment/management; it will go to PAAB to confirm exemption status. Can these two campaigns contain similar creative elements?
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Hey @copycallosum
At the core of this question is linkage principles. When a DTCI campaign (including help-seeking) contains the same creative concept/elements (visuals/look/feel) as a HCP-targeted piece, this creates a linkage between these two pieces. Assuming the DTCI campaign discussed pharmacotherapy options (not solely non-pharmacologic therapy options), there is now a linkage to pharmacotherapy to the HCP piece (even though the HCP piece did not directly discuss pharmacotherapy). As such, the HCP piece will not be exempt from PAAB review, as it is linked to another piece discussing pharmacotherapy.
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@jennifer-carroll Ah, that makes sense! So, if the DTCI campaign did not include ANY mention of disease management (the CTA would be something like "talk to your doctor if you've experienced any of these symptoms"), does that change your answer? In that case, could the creative be the same for both audiences?
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Hey @copycallosum
It’s difficult to capture all aspects that may make this activity exempt versus an advertising/promotion system (APS) subject to pre-clearance review without seeing all the tools and how they are used.
The general response is that when you link advertising (APS) and non-advertising, everything becomes advertising (this is regardless of whether it is branded or unbranded). If HCPs are being encouraged to link disease state information to a consumer campaign, all aspects of the consumer campaign should be considered in the context of the dual audience (HCP and consumer). We’d suggest submitting for opinion as mention of management can be implicit or explicit and is broader than just mention of a product/brand.
