719 - With regards to question #645, the question asked about repurposing a piece approved for DTC use with "potential patients". Is a potential patient not viewed as a consumer? I thought the definition of patient was restricted to those who had already been prescribed a drug. I had previously been advised by a PAAB reviewer that pieces for "potential patients" would be reviewed as DTC. Could you please clarify the differences in these audiences? Thank you.


  • In differentiating between consumers and potential patients (someone who has not yet been prescribed a drug), the mode of distribution becomes an important factor. In the scenario describe in question 645, the DTC piece is now distributed through HCPs to potential patients. The interaction has now changed to a counselling tool in which the healthcare professional selects the appropriate patient audience in the context of a condition. As the audience has changed to patients, the content is now subject to the standards of the PAAB code. As a result, the rigors for quality of evidence change.