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163 - Is there any issue in company representatives handing out invitations to online medical education programs that have received accreditation?
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This activity is not necessarily a PAAB issue. See the Innovative Medicines Canada code section 8 about representatives activities and distribution of materials. CME can contain off-label claims which a company cannot legally promote. So is the rep promoting those claims by directing a viewer to that CME? The PAAB code covers materials, and thus it depends on the content of what is being handed out.
Two schools of thought prevail here. One is the rep acting as courier. The second is if representatives are paid to sell product, why are they involved in a nonpromotional CME activity? They are creating a selling opportunity through the use of a specific CME event, thereby linking a promotional activity to a nonpromotional activity. Reps could promote the company CME service and not individual programs.
We believe the more ethical road that stands up to public scrutiny and possibly avoid regulatory jeapardy is the latter.
