Bayer: ‘Guidelines in Practice’ commissioned videos not ruled disguised promotion for Xarelto (AUTH/3322/3/20)

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Key facts

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Case number	AUTH/3322/3/20
Company	Bayer
Complainant	A concerned UK health professional
Medicine	Xarelto (rivaroxaban)
Material	Two commissioned videos hosted on the ‘Guidelines in Practice’ website
Allegation	Disguised promotion
Clause(s) considered	Clause 12.1
Decision	No breach
Complaint received	10 March 2020
Case completed	17 June 2020
Applicable Code year	2019
Appeal	No appeal

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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A UK health professional complained about two videos hosted on the ‘Guidelines in Practice’ website: ‘Secondary event prevention and risk stratification in patients with symptomatic peripheral arterial disease’ and ‘Secondary event prevention and risk stratification in patients with stable coronary artery disease’.
The videos were commissioned by Bayer and linked to Xarelto (rivaroxaban) prescribing information.
The complainant alleged the videos were disguised promotion because the disclaimers did not explicitly state the content was promotional; the only “clue” was the prescribing information link and wording such as ‘commissioned’ and ‘suggested the topic’.
The PMCPA asked Bayer to consider the requirements of Clause 12.1.
Bayer said the webpages were commissioned and certified for promotional use, included prominent ‘Commissioned by Bayer plc’ wording at the top, a prominent ‘View prescribing information’ link, and a detailed sponsorship declaration at the bottom; similar disclosures and the Bayer logo also appeared within the videos.

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