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79 - Could you please provide some clarity around the definition on Formulary Kits as described in "The Distinction Between Advertising and Other Activities". Specifically, is it appropriate for a company's sales representative to distribute formulary kits to formulary committees in a hospital setting?
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Sales representatives can deliver formulary kit information if the information has been requested by the hospital i.e. if the hospital has standard requirements and criteria for formulary listing requests and the company is meeting the request for that information. If the reps are promoting the product with information in the kit that is beyond the requested information, the company should seek PAAB review. If the audience is broader than the hospital requesting the information for formulary listing, then it would be considered to be advertising. See the "Distinction Between Advertising and Other Information" (Health Canada) for the HC policy. The PAAB has received a complaint from a formulary committee that was bombarded with information beyond what they requested.
