Hi, I am looking for a ruling on the following scenario. If a sales rep is using a PAAB approved, Un-branded, Disease state promotional piece to engage an HCP in a non-product related discussion. If, during that discussion, the physician asks that representative a product specific question, i.e. « What is the clinical data for Product « X » in the disease state we are discussing?”. Is the rep allowed to answer the question and switch to a product based discussion that incorporates PAAB approved promotional pieces? What specifically can the rep do in a situation like this where the use of PAAB approved messaging and promotional pieces are strictly reactive?

The PAAB code relates to APS content. It does not govern specific rep activities. In order to stay in scope, I’ll refrain from discussing specifically when particular rep activities are appropriate or not.
Q&A # 232 should be interpreted as conveying the importance of not setting out to link branded and unbranded pieces in principle (this principle applies regardless of whether we are talking about journal placements, web contexts, rep detailing, etc…).  Unbranded APS often have content which is off-label in relation to the sponsor’s brand (in fact, this is often why the piece is unbranded in the first place). Creating the link often equates to off-label promotion. 

The Rx&D code has provisions against proactive/solicited off-label promotional activities.


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