Clarification on indication inclusion in multi-Product APS
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We are developing a multi-product lowest level APS regarding a Patient Support Program (PSP) for enrolling patients into the PSP via website (online portal). The APS is generalized, one page document with several product names and instructions to access the website and contact numbers. No therapeutic or Pharmacologic claims are available.
Therefore, could you please clarify whether it is acceptable if the indication statement is not included in this piece. Thank you. -
Good Morning @Supriya
We assume that you are referring to a patient targeted APS. As a patient would not have a prescription for all the products, this would contravene the direct-to-consumer advertising (DTCA) regulations (Section C.01.044 of the Food and Drugs Act Regulations) to create a link to the therapeutic use (i.e. indication could not be included) for products they are not prescribed. While the three base levels of fair balance apply only to HCP-targeted APS, a weblink to the Terms of Market Authorization (TMA) links the therapeutic use, a violation of the DTCA regulations.
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Thank you Jennifer. The website is exclusively intended for healthcare professional and is not designed for patient use. Therefore, we seek clarification on whether the inclusion of an indication statement may be deemed unnecessary, given that the material does not contain any therapeutic or pharmacologic claims.
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Hey @Supriya
This appears to be a specific question about a specific piece. The piece should be submitted for assessment. The forum is for general questions. As an example, a general question here might be “Is the inclusion of an indication statement required in materials directed exclusively to healthcare professionals, where no therapeutic or pharmacologic claims are presented”. The answer to this question would be, that the indication is not required when there are no marketing benefit or therapeutic claims (see Marketing benefit claims: What are they and what level of support do they require?).
