554 - On an HCP gated website that provides branded drug information, is it mandatory that the very first page after the gate is cleared be the "safety information" for that drug? Assuming the "safety information" link is accessible from the main navigation menu, can the landing page after the gate be some other content? Thanks.

  • When assessing safety information or fair balance requirements, particular care is required for tools like websites as it is difficult to predict the path in which the information will be consumed. Additionally, the entire content is not typically consumed in one sitting. The simplest way to ensure physicians are exposed to the required fair balance copy is to include it on the brand product homepage. Linking middle level to highest level of fair balance on the homepage is an option which may help address space issues. Inclusion of a “Safety Information” menu item on every screen cannot replace the fair balance requirements described above. Please refer to the guidance document “Guidance on Base Fair Balance Level Selection and Placement” for more information.