Is the following service exempt from PAAB review, as we think it does not meet the the criteria for a promotional activity. A pharma company would use a vendor to include a link to a peer-reviewed, on-label, full publication for their approved product, on a website other than the journal in which that publication was published. The vendor has agreements with other health websites which are frequented by physicians and other HCPs. Some of these sites are also other medical journals. The link to a recommended article would be disseminated via a targeted approach - it would only be displayed to potentially interested physicians (eg/a certain specialty, only Canadian HCPs). the link is also clearly market as being driven by the vendor, and is labeled as being "recommended reading/other articles you may be interested in". The physician makes the decisions to click the link to be redirected to the other peer-reviewed article. The link could be time-limited, rather than an everlasting link. It could be limited to a certain number of clicks on the link or to a defined time period (ex/ 3 or 6 months). (see example https://ascopubs.org/doi/abs/10.1200/JCO.20.01366. Look at the grey vertical bar to the right "We Recommend")

Duration of the link, number of click, etc. would not be what renders this activity advertising or not. The nature of the link and the association that it creates could render it advertising. For example, paying to have a link to a study which favours the sponsors product in the context of a competitors study, could be considered advertising and may not be acceptable. Likewise, placing a recommended link to a study about the sponsors product in the context of a disease state or epidemiological study may also be considered advertising and would require the assessment of the appropriateness of the link. While this link could happen organically, when the sponsor influences this association, it may be considered advertising.


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