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Home / promotion guidelines

November 24, 2010

MSWatch.ca makes a comeback: Now within Canadian Rx-DTC guidelines

By marketing4health in Canada's Online Health CheckCase Study: Canadian Healthcare Social MediaPharmaceutical Marketingsocial media

Last month, I posted an article about the removal of the MSWatch.ca online forums. Many people around the world responded to me stating that they felt it was the MS patients who had lost the most from this changed website. I agreed. On Monday November 15 2010, I was delighted to receive another e-mail from MSWatch.ca, this time welcoming me to the new MSWatch Oasis:

Tell your friends: Twitter Facebook MySpace Digg StumbleUpon Delicious
There's a place that we go to for comfort after a long day, where can help find some relieft and peace. It could be your favorite part of the couch, the smell of fresh baked cookies or a phone call with a loved one. Whenever you're there, it's as if you're transported away.  Today we're exited to announce that there's something new on MSWatch, a place where you can help build a world of understanding and support for the MS community. Introducing your MSWatch Oasis
Keep track of your treatments and help manage your appointments in a fun and engaging way.
Perch in the tree where you can find resources in the birdhouses and check in on fellow Oasis members.
Chirp others in the tree and check in on your buddies.
Earn badges just by keeping up with appointmens and therapy.
Update your profile to connect with others in the MS community. Add links to your Facebook, Twitter, blog and website.
Join in to help manage your treatments, connect with other patients and caregivers, and access learning resources and helpful tools. Help build a world of understand and support.  Visit the MSWatch Oasis
So I decided to take a look at their new site.  I was able to sign in with my username and password from the original MSWatch.ca online forums.  After I logged on, I had the opportunity to let the community members know how I was feeling by selecting one of several pre-written statements.  This protects the pharma company from statements that could suggest an adverse event or one that could fall outside of Rx-DTC guidelines: Then, I was prompted to update my personal profile.  As part of the profile, I could include my blog website, Twitter username, and FaceBook page.  This is a very interesting feature because it allows members of the community to meet each other on the MSWatch Oasis and then take their conversation onto their personal networks, where they are free to discuss all aspects of their disease and treatment.  Justin Seiler, Electronic Media (Marketing) Associate at Teva Canada Innovation, told me that MSWatch wanted to act as a 'hub' for their MS members.  That way, they are facilitating networking amongst the members, yet forcing them to go on third party sites.  As such, Teva Canada Innovation does not hold any responsibility of the discussions held off their site. Although direct communications between members do not occur onsite, you can see which community member is in the "Oasis".  In fact, you can click on the person's username to gain access to a limited portion of their personal information, including hyperlinks to their websites, Twitter and FaceBook profiles (assuming the member has updated their profile with this information): Another very useful tool consists of the calendar which allows patients to input their treatment days as well as their appointments.  And as you can see in the pic below, community members can also 'label' themselves with a particular type of bird.  This is a great way to start a conversion with other community members (offsite, of course). Although I did not find this on the site itself, I did find it as part of the 'tour' of the website:  badges.  It appears as though community members can earn different badges depending on what they actually do on the site.  Unfortunately, I was not able to see the range and meaning of the different badges. Going through the website, everything looks to be within Canadian pharmaceutical promotional guidelines, including Rx-DTC (where we are only allowed to mention product name, price and quantity).  Brands mentioned under treatment options include all of the players within this category, including a link to their individual support groups. Congratulations to Teva Canada Innovation for not giving up, and for finding a way to allow MS patients to continue to share with one another while staying within the Canadian Rx-DTC guidelines.  By maintaining the ability to help the MS patients network with one another, Teva Canada Innovation continues to achieve its strategic objective.  This is a valuable service for MS patients and I look forward to watching it grow quickly (as did the original MSWatch.ca online forums).  You have proven yourself to be a social media leader within the Canadian pharma industry! The agency that worked on the look and feel of the MSWatch Oasis is Twist Image. This is the agency that was also involved in the redesign of MSWatch.ca that took place in 2009. Do you think the MSWatch Oasis is an effective social networking tools for MS patients?  Why or why not? Stay in touch, Natalie Connect with me on the following networks: FaceBook, Twitter, LinkedIn

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January 21, 2010

Canadian Pharma/Healthcare Regulatory Guideline Revisions – Jan 2010

By marketing4health in Pharmaceutical MarketingResources

Love them or hate them, as a medical marketer, you have a ton of regulatory guidelines to follow.  And they seem to change on a regular basis (some guidelines change more frequently than others).  In this blog post, you will find a list of some of the Canadian healthcare guidelines with links that will lead you to the document(s) of interest. The only revisions that took place in January 2010 are in the Rx&D code (see below for details of these changes).  A few other revisions for other sets of guidelines are expected over the next couple of months.  Although the details on the other revisions have not been shared with me, I made a note of when the revisions are expected to take place. NOTE: If you have marketing collaterals or campaigns that need pre-clearance, but you are not sure which regulatory body to contact, take a look at yesterday's post; Algorithm on choosing the appropriate Canadian healthcare regulatory guidelines. ------------------------------------------ New 2010 Rx&D Code of Ethical Practices (not yet posted on the Rx&D website, but coming soon). Here's a peak at the upcoming changes.  Only section 15 has been revised in the 2010 code: Section 15.4 Penalties

  • In 2009, the 1st, 2nd and 3rd code infractions were published in the Rx&D Update.  As of 2010, these infractions will be published on the Rx&D website.  All postings will remain on the website for 24 months from the date of the final decision.
New section 15.4.1 Compliance Statement (3 statements as part of this new section)
  • Within ninety (90) days of the final decision date with respect to any Code infraction, the Member must clearly indicate in writing to Rx&D that they have halted the activity or otherwise addressed the issue that caused the infraction. A copy of this compliance statement will be posted on the Rx&D website with the relevant decision of the IPRC.
  • In the event that Rx&D determines that the Member has not complied with this requirement, the Member will be deemed to have deliberately contravened one of the Guiding Principles, and the penalties set out in Section 15.3, 15.5.1 and 15.5.2 will apply.
  • In exceptional circumstances, a Member, acting in good faith, may believe that more than ninety (90) days will be required to comply with this Section 15.4.1. In this case, the Member must file a written extension request with Rx&D within ten (10) days of the decision date, providing a detailed supporting rationale for the request, and an estimate of the time required. Rx&D will forward the extension request to the IPRC who will evaluate the extension request and make a recommendation to the Rx&D Executive Committee (EC) within ten (10) days of its receipt. The EC, in its sole discretion, may elect to grant such an extension to the Member.
-------------------------------------- Pharmaceutical Advertising Advisory Board (PAAB)
  • Several supplementary guidelines to the PAAB code exist.  A recent example; "Guidance for Advertising/Promotional Systems (APS) Which Are Openly Visible in Healthcare Professional (HCP) – Patient Interaction Areas"
  • Recently, PAAB has implemented the Health Canada document Interim Guidance on Fair Balance in Direct-to-Consumer Advertising of Vaccines
  • You might also want to look at the PMCQ website for a list 100+ PAAB FAQs.
  • No changes in the PAAB code.
  • No changes in prescription DTCA guidelines
Canadian Association of Medical Publishers It does not appear as though any new guidelines have been posted, since at the bottom of the CAMP advertising guidelines page, the last update appears to have been on May 11 2009. MEDEC-Canada's Medical Technology Companies Revisions scheduled for March 2010. Consumer Health Products Canada (previously NDMAC) No changes, but expect some to come once their new website (along with new organizational name) gets launched within the next month or so. Advertising Standards Canada (ASC)
  • Any change in ASC guidelines would be from a result of changes with the Health Canada documents.  Since there have been no changes for the Health Canada documents, there have not been any changes for the 'Consumer Drug Advertising Clearance' documents of either the Prescription drugs or the Non-prescription / Natural health products (see the two boxes on the left of the ASC screen which allow you to choose the documents required based on the product type).
Health Canada’s documents regarding direct-to-consumer (DTC) advertising of prescription drugs
  • Note that both PAAB and the ASC can provide an advisory opinion on DTC collaterals and campaigns.
  • No changes for any of the following documents.
  • The Distinction Between Advertising and Other Activities
  • Advertising Campaigns of Branded and Un-branded Messages
  • Product Package Representations in Branded Prescription Drug Reminder Ads Directed to Consumers
Health Canada’s documents regarding direct-to-consumer (DTC) advertising of non-prescription drugs
  • ASC and MIJO can provide preclearance services with respect to consumer advertising of non-prescription drugs and natural health products.
  • No changes for any of the following documents.
  • Consumer Advertising Guidelines for Marketed Health Products (for non-prescription drugs, including natural health products)
  • Therapeutic Comparative Advertising: Directive and Guidance Document
  • Principles for Claims Relating to Comparison of Non-therapeutic Aspects of Non-prescription Drug Products
------------------------------------ Note that I am not a pharmaceutical regulatory expert.  I am providing these resources as a service to my blog’s readers.  If you have specific regulatory questions, please contact the appropriate organization.
Stay in touch, Natalie Connect with me on the following networks: FaceBook, Twitter, LinkedIn
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