Section 12: Interactions with the General Public

  • Code Info Sessions

Disease Awareness and the Code – August 2023

5:23 What does the Code say about disease awareness?
7:08 How is disease awareness defined?
27:21 Practical tips to ensure a disease awareness piece is Code compliant
38:10 Disease awareness when only 1 treatment in that disease area
50:50 Social media and disease awareness
1:03:29 What are some examples of disease awareness?

Interactions with non-healthcare professionals and the Code – June 2023

6:00 What does the Code say about non-HCP interactions?
20:54 Unpacking Section 11 – Stakeholders
31:39 HCO support considerations
40:18 Unpacking Section 13 – General public
42:47 Media releases
46:56 Social media
49:03 Medical information
51:49 Patient Aids
53:25 Disease awareness campaigns

  1. Consumer Medicine Information, risk management materials and Product Information are credible, non-promotional sources of information about a Company’s products. A Company may make these documents available to members of the general public, providing they appear in their entire form and are not amended, abridged or displayed in a promotional manner.
  2. Requests from individual members of the public for medical advice on the diagnosis of disease or choice of therapy must always be refused and the inquirer recommended to consult their doctor.
  3. Where a specific request is made by a patient or a member of a patient’s family about a product which has been prescribed, the Company may clarify matters in a non-promotional manner using the Consumer Medicine Information, relevant risk management materials or apatient aid and should otherwise recommend inquirers to consult their doctor.
  4. Product-specific programs, product information, and patient aids should be provided only to patients already prescribed the product and must not be promotional. Items that are likely to be used outside the home, and thus visible to the general public, may be branded with a Company name and/or a Company logo only.

12.1 Promotion of Medicine Delivery Devices to the General Public

Promotion of a medicine delivery device to the general public is permitted in restricted circumstances.

  1. Promotion of a medicine delivery device which is used for the administration of a prescription medicine (including Schedule 3 medicines that are predominantly prescribed by a medical practitioner) and that is distributed independently from the active ingredient, is permitted as long as the medical device is not branded with the name of a particular medicine. The device must be included on the ARTG as a medical device.

12.2 Educational Information and Disease Awareness

It is acknowledged that members of the general public should have access to information on medical conditions and the treatments which may be prescribed by their doctors. The purpose of such information should be educational and should encourage patients to seek further information or explanation from the appropriate healthcare professional.

In addition, the following criteria should be satisfied:

  1. The information may include descriptions of the therapeutic category including classes but does not include any reference to a specific prescription product.
  2. The information should be presented in a comprehensive, balanced and fair manner that does not unduly emphasise particular options or the need to seek treatment.
  3. The emphasis of the educational information should be on the condition and its recognition rather than on the treatment options. The appropriate treatment for an individual patient is for the healthcare professional to decide, in consultation with the patient, and this should be clearly stated.
  4. The tone of the material must not be presented in a way that unnecessarily causes alarm or misunderstanding in the community nor stimulate the demand for prescription of a particular product.
  5. If readers of online material are referred or linked to other reputable information sources that the Company has not developed, before the information can be accessed a statement covering the following information, where relevant, should be displayed: 
    1. the information they are about to be referred to may not comply with the Australian regulatory environment;
    2. if relevant to a product, readers should refer to the CMI to understand the terms of a product’s registration in Australia;
    3. the intent of providing this further material is informational and not as advice; and  
    4. any information provided by this source should be discussed with their healthcare professional and does not replace their advice. 
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