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C

Constance

@Constance
PAAB Notice
The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.
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Recent Best Controversial

  • Price Comparisons
    C Constance

    hi Paab!

    I would like to develop an APS to highlight all of the Rx products we have in our portfolio (all with the same indication). Provided I can find a compared prices must come from a single independent source (as described in question 438), would I be able to present the price as a unit cost? For example, the price of injectable pen X is $450 for 450 units, i.e. $1/unit.

    Claims & Support/References for Claims

  • 330 - Does "coming soon" on an approved product require PAAB approval?
    C Constance

    @jennifer-carroll does this also apply to a new indication of an already approved product? In other words, "New indication coming soon"

    FYI post-approval change/preclearance exemption/what requires review/PAAB scope

  • PAAB AI TOWNHALL – December 19th, 2024
    C Constance

    @Jennifer-Carroll just following up on this.

    Blogs external ai artificial intelligence townhall industry feedback

  • PAAB AI TOWNHALL – December 19th, 2024
    C Constance

    Thank you, PAAB, for the informative town hall on December 19. After reviewing the communique, I have a few follow-up questions:

    • Is Phase 1 complete, or are there additional steps before it goes live? If there are additional steps, what are they, and what is the expected go-live date?

    • What level of understanding do manufacturers have regarding this initiative? As their agencies, is it our responsibility to bring them up to speed, or is that the purpose of the debrief meeting?

    • Could you please clarify who should attend the debrief meeting you are suggesting? Should both agencies and manufacturers be present?

    Regards,
    Constance

    Blogs external ai artificial intelligence townhall industry feedback

  • reporting criteria for special authorization products
    C Constance

    Hello PAAB! In cases where provincial formulary coverage of a product is restricted (e.g., special authorization) do all of the coverage criteria, definitions, and notes have to be included with the APS or can you simply link to them (via a "See Coverage Criteria" button) on the corresponding page on the provincial formulary web site. As well, if a criterion is one where we have no data in our PM, do we have to disclaim the criteria in some way? (i.e. "Product X has not been studied for this criterion"?

    Claims & Support/References for Claims

  • 713 - Can ongoing studies for a group of products (same therapeutic category) be discussed in a Corporate APS, or must this be done in individual branded APS? For example, a company has a portfolio of diabetes drugs that with ongoing research into weight loss indications, and would like to produce a single piece discussing all trials.
    C Constance

    @jennifer-carroll if a group of products could potentially be presented in a single co-promotional tool, as you mention above, can you please elaborate on what you mean by: "with the information relating to each individual brand being separate and distinct"? And to be clear, I am asking about how information from the TMA gets presented, not the ongoing trials.
    For instance, do you mean that info from the TMA (i.e. efficacy, safety, dosing, MOA, etc.) relating to each individual product/indication has to be presented as a separate and distinct module within the co-promotional tool?
    And are there any considerations you can share when it comes to presenting a group of products/indications within a single APS?

    Claims & Support/References for Claims

  • 663 - Can baseline patient demographics (not outcomes) captured by Patient Support Program enrollment be used in HCP-directed advertising, in a promotional or claim-neutral manner?
    C Constance

    @jennifer-carroll would demographic information like the number of patients enrolled in a PSP by province or by gender or by age be permitted in HCP directed advertising?

    Claims & Support/References for Claims

  • 537 - Can a sales rep use a slide deck that discusses the study design, inclusion/exclusion criteria, and patient characteristics for study in an indication for which they don't yet have approval?
    C Constance

    @jennifer-carroll Assuming a product has several ongoing trials as per the PAAB definition of "ongoing", can the APS include study design, inclusion/exclusion criteria, and patient characteristics? I don't believe this part of the question was addressed. More specifically, within a branded APS (like a detail ad) can tab be added, away from the clinical data, with a table describing all ongoing trials.

    Claims & Support/References for Claims

  • Creative Imagery Committee
    C Constance

    @jennifer-carroll if there is an opportunity for us to contribute to this (send in our examples), please let me know.

    Blogs

  • Before-after images from real world patients in branded context
    C Constance

    @jennifer-carroll assuming the patient profile meets all these conditions, does it have to be a real photo, or would an AI generated image based on the before and after clinical results for patient be acceptable?

    Claims & Support/References for Claims

  • Creative Imagery Committee
    C Constance

    @jennifer-carroll Checking in on this again. Any developments?

    Blogs

  • RWE and Code Update News
    C Constance

    @jennifer-carroll this is excellent news. I read the guidance document today.

    Announcements external rwe guidance

  • Creative Imagery Committee
    C Constance

    @jennifer-carroll has there been any further developments on the Creative Imagery Committee? I searched the PAAB web site but did not find anything further on this topic.

    Blogs

  • 766 - Can you confirm if a CSR (Clinical Summary Report) is an acceptable document to support a data presentation from a published clinical trial. For example, the published clinical report presents pooled data results but the CSR captures this same endpoint by individual pivotal studies which garnered NOC for the drug. Additionally, can client share a portion of the document rather than the entire document given these reports are typically 2000+ pages. If it is possible to submit a partial version of the report, please confirm what parameters should be considered. thank you.
    C Constance

    Good afternoon @jennifer-carroll! Point well taken about the circumstances under which a CSR can be used as evidence, but what about the second part of this question? If we able to submit a partial version of the report, can you confirm what parameters should be considered? Thanks!

    Claims & Support/References for Claims
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