293 - A pharmaceutical company has provided an unrestricted educational grant for the development of a disease-focused patient website. Can sales reps distribute postcards promoting the website (site name, disease focus, URL)?

  • From your question, it would appear that the piece is intended to be non-promotional. Assuming this to be the case, it is important to consider that distribution factors can render non-promotional content to be subject to the advertising regulations. As a general rule of thumb, if you want something to stay non-promotional, don't add promotional elements (e.g. promotional cards, drug reps...etc). Having said this, drug reps may distribute a postcard promoting this type of website to HCPs, but this would render the website subject to PAAB review (i.e. we'd review the card and the website). Note that the card should be non-branded if the site is non-branded. Also note that drug reps should not distribute content directly to patients.