682 - If we create a survey asking about the impact of using intravenous vs. subcutaneous drugs on clinic/hospital resources (personnel, time, money) - and we don't mention the therapeutic area, disease state or a specific drug (neither brand nor non-proprietary name will be mentioned), would this survey be exempt from PAAB pre-clearance?
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Creation and administration of legitimate market research as described in your question, would be outside of the scope of the PAAB code. However, if the intent is to include the survey results in advertising then the survey methodology and results would fall under the scope of the PAAB code. Use of surveys in advertising should be restricted to non-clinical features of a product. As clinic/hospital resources (personnel, time, money) would be considered pharmacoeconomic claims and therefore fall under clinical claims, a survey would not be considered an acceptable source to support these types of claims. We suggest submitting the survey questions to PAAB for review prior to conducting the survey if the intent is to use the results in advertising. For more direction on the creation and use of surveys, we suggest reviewing Ask PAAB questions 590 and 551. (As a courtesy, search “survey”)
