372 - When advertising to the HCP target via appropriately gated sites, what are the restrictions around static content? Can a drug ad be placed within relevant content? or target the content on the site specifically?

  • At times, ads for healthcare products are intended to be placed in proximity to particular HCP gated content. Whether this is acceptable or not hinges in whether the linkages which are generated in so doing meet legal requirements and the PAAB code standards. PAAB should be informed of all intended links at the time of initial review of the ad in order to make the needed assessments. If the piece had already been reviewed as a standalone piece with run-of-site, it should be resubmitted as a new submission so as to be assessed within the new specific context. For example, in cases where you intend to place an ad next to a specific article, we should be informed of that article (it should be provided as a reference for or review of the advertisement if the article is generated independently, whereas it should be provided as a submission if the manufacturer generated it). As a second example, if you are selecting tags, these should be provided as part of your initial submission for the piece.

    By ‘within’ I presume you mean that the ad is breaking up the content but it is clear where the ad begins and ends (and that the ad is clearly separate and distinct from the other content). Ultimately, you’d be misleading the audience if it is not obvious that the piece is advertising and if it is not obvious where the advertising begins/ends. ALSO note that the underlying content is no longer “independent” (exempt from review) if the manufacturer is selecting break points in that content for insertion of drug advertising.