Question 293
A pharmaceutical company has provided an unrestricted educational grant for the development of a disease-focused patient website. Can sales reps distribute postcards promoting the website (site name, disease focus, URL)?
From your question, it would appear that the piece is intended to be non-promotional. Assuming this to be the case, it is important to consider that distribution factors can render non-promotional content to be subject to the advertising regulations. As a general rule of thumb, if you want something to stay non-promotional, don`t add promotional elements (e.g. promotional cards, drug reps...etc). Having said this, drug reps may distribute a postcard promoting this type of website to HCPs, but this would render the website subject to PAAB review (i.e. we`d review the card and the website). Note that the card should be non-branded if the site is non-branded. Also note that drug reps should not distribute content directly to patients.
