The FDA has announced the availability of a draft guidance for industry entitled, "Promoting Medical Products in a Changing Healthcare Environment: Medical Product Promotion by Healthcare Organizations or Pharmacy Benefits Management Companies (PBMs)." This document provides guidance to the pharmaceutical industry and other sponsors of regulated medical products by describing circumstances in which they may be held responsible for promotional activities performed by health care organizations or PBMs.
Nightingale SL. Promotional Practices of Pharmacy Benefits Management Companies. JAMA. 1998;279(9):645. doi:10.1001/jama.279.9.645
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