TGA updates COVID vaccine advertising guidelines for GPs

Anastasia Tsirtsakis

3/08/2021 4:17:43 PM

Those taking part in the rollout now have permission to advertise the vaccines, including brand names, and can offer incentives.

People walking past signage at a general practice.
Practices can now create their own advertising materials, including the brand names AstraZeneca and Pfizer. (Image: AAP)

The update, issued by the Therapeutic Goods Administration (TGA) on 30 July, has been dubbed a ‘sensible’ step forward in helping GPs communicate with their patients about the COVID-19 vaccines, and address any hesitancy.

The RACGP has been calling for clarity and more freedom since early March, when the TGA first restricted how medical professionals could promote the COVID vaccines.
Under the 2021 permission, the TGA allows ‘an approved COVID-19 vaccination provider’ to develop their own materials to communicate publicly about the vaccines with reference to ‘trade names, or active ingredients, of the therapeutic goods’.
Professor Mark Morgan, Chair of the RACGP Expert Committee – Quality Care (REC–QC), told newsGP he thinks it is ‘about time’ given the widespread community knowledge about the vaccines.
‘They’re known as the Pfizer or the AstraZeneca … and those terms are used in all the media. So it would be very false to restrict clinics from producing materials that specify the availability of those particular vaccines,’ he said.
‘We should be using their names if that’s what the population knows them as, and that’s who you’re trying to communicate to.
‘It [also] allows practices to develop messaging for their particular populations without being so worried about infringing what seemed like a fairly arbitrary rule. That’s including developing messaging in languages that suit the population.’
Any self-developed advertising materials, however, must be consistent with current Commonwealth health messaging regarding the vaccination program. They also must not contain:

  • any statement, or implication comparing different COVID-19 vaccines (or comparing vaccines with treatments such as medicines)
  • statements to the effect that COVID-19 vaccines cannot cause harm or have no side effects
  • any statement regarding COVID-19 vaccines that is false or misleading.
To help GPs understand the new permission, the TGA has included an example scenario, where a doctor has been compliant:
‘Dr Smith posts on the clinic’s Facebook page a statement indicating that they support the Government’s vaccine rollout and encourages their eligible patients to be vaccinated. Their post includes a link to information from the Australian Government Department of Health website, along with logistical information, including the opening hours of their COVID-19 vaccination clinic and the brand of vaccine they administer.’
REC–QC member, Dr Magdalena Simonis said the TGA’s decision will also help to take the pressure off ‘overwhelmed’ front office staff.
‘Every practice has been inundated [with] “Are you getting the Pfizer?” And some practices are, and some practices aren’t,’ she told newsGP.
‘But unless you advertise, they don’t know that you do AstraZeneca and Pfizer. This is going to simplify a lot of that for patients, and it’s going to simplify a lot of the noise that’s created at the front desk for the staff and for GPs.’
While it is not permitted for the advertising material to compare AstraZeneca and Pfizer, the TGA has clarified that the guidance ‘does not apply’ to information shared between a health professional and their patient during a consultation.
‘For example, if a patient asks their doctor during a consultation about the relative merits of each vaccine and which one is suitable for them, the doctor can advise the patient without risk of breaching the advertising laws,’ the TGA states.
Practices are also permitted to share a statement that they do not have stock of a particular vaccine, as well as sharing ‘factual and balanced’ information about the vaccines from reputable sources on social media.
In addition to the expanded advertising criteria, the TGA’s 2021 permission allows health professionals taking part in the rollout to offer incentives to fully vaccinated patients. However, the offer is subject to the following conditions:
  • It must contain a statement to the effect that the vaccination must be undertaken on the ‘advice of a health practitioner’
  • Rewards must not include tobacco or medicines, other than listed medicines
  • The offer must only refer to COVID-19 vaccines generically – ie not by trade name or another reference to a particular vaccine, such as ‘the mRNA vaccine’
  • It must be made to all eligible people who have been vaccinated, not only those people vaccinated from the date of the offer
An example, cited by the TGA, is the offer of a free health check:
‘Uptown Medical Centre and Pharmacy publishes a Facebook post offering a free health check to anyone who has been fully vaccinated under the national COVID-19 vaccination program. The offer includes a statement that it is only valid for vaccinations undertaken on the advice of a health practitioner.’
Professor Morgan said while incentives offered at a government level to reduce barriers to vaccination are a good idea, he is concerned that for general practice, offers could have ‘unintended consequences’.
‘It’s a potential minefield because you could end up with patients shopping around for the best incentives and then actually delaying uptake,’ he said.
‘The benefits of the vaccine for protecting people from serious illness from the probable benefit of reducing spread and the very clear benefit of protecting yourself as an individual from serious disease, I would have thought, would be the incentives to concentrate on.’
The new arrangements will cease on 31 December 2022.
Prior to the update, health professionals had been given the green light to develop their own materials about COVID vaccination in June, provided the content did not contain references to specific brands.
‘Ordinarily, health professionals are not allowed to endorse a medicine or other therapeutic good. However in the context of the pandemic, and under the 2021 permission, this prohibition does not apply to registered COVID-19 vaccines,’ the TGA states.
As the main providers of vaccination, Dr Simonis says it is important GPs are empowered to engage with their patients given the risks that the Delta variant is posing.
‘We’ve not been given much in the way of autonomy in this particular process and rollout; we’ve been given permissions, but only incrementally and in a stepwise fashion,’ she said.
‘I think what the [Federal] Government and the TGA have realised is that we are at the helm of helping our vaccine hesitant patients cross the line, and in being able to let our patients know that we are providers of the vaccine, we’re making a statement about how comfortable and confident we are around this, and that we’re also part of this big solution.’
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