577 - Hi - I understand that as per Section 6.6iv, an email informing HCPs about 'updated provincial formulary criteria for Drug X' would be considered PAAB exempt (if there were no linkage to therapeutic or promotional claims). Could you provide clarification on whether including a website link to the full formulary list of a province would still be considered exempt? Note that this formulary list contains criteria specific to Drug X.
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The essence of PAAB code section 6.6iv can be found in section 1.5 now, and states “A message comprised only of the words “now on provincial formulary” (or equivalent) in a manner which is not linked to a therapeutic message in any way”. In addition, the PAAB advisory document “Provincial Formulary Coverage Statements” further states “APS comprised only of “Drug X: Now on OBD formulary” not linked in any way to additional product messages or disease/corporate messages”. As such, a direct link to the coverage criteria for drug X would require review.
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As a follow-up to Q&A 577, we understand inclusion of the written statement “See Formulary listing for more information” would still be exempt for a simple “Now on Formulary” Email. Can you please advise if an indirect link to a general Formulary/Provincial homepage would maintain this exemption? The Sponsor has done their diligence in not directly linking to the therapeutic use, and the onus would be on the HCP to seek out the product information (if desired) through the Formulary.
