391 - Are notes to HCPs allowed to be attached to PAAB material or approved studies. If not, where is this referenced in the code.

  • PAAB approved ads should be used exactly as approved otherwise it’s not really “preclearance” (e.g. without modification through inclusion of additional notes affixed to the piece). Affixing notes to independently generated materials could cause them not to be exempt. It is a best practice to have clear internal regulations either prohibiting use of notes in this manner or explaining the limited cases in which such notes can be used (e.g. best to restrict this to administrative notes like “sorry I missed you” and/or contact info).