411 - Is it within regulation for a pharmaceutical company to disseminate information through patient groups (as opposed to through a health care provider).
-
Yes provided the patient information is non-promotional and consistent with Part III of the PM (as we’ll ensure during the PAAB review). The operative word is 'patients' (i.e. individuals who have been prescribed the medication). Keep in mind that the distribution of manufacturer sponsored patient information for prescription drugs to a broader audience (whether by manufacturer or on behalf of the manufacturer) would appear to contravene C.01.044 of the Food and Drug Regulations as these materials likely exceed the restriction to name, price, and quantity. Particularly when systematic distribution is motivated by a contractual arrangement between the manufacturer and the patient group rather than the result of medical decisions made by HCPs as they perform their professional activities in the best interest of their patients.
