Valued TPMO Partners,
On Friday 9/16, HPMS showed TV commercials/advertisements submitted to CMS required a 45-Day Review period for approval or disapproval of the material. We immediately sent an inquiry to CMS, as this differs from the previous submission type of 5 day File and Use, with no immediate review by CMS at time of filing.
On Monday 9/19, our Compliance Team received a response to our inquiry asking to confirm this change in HPMS. CMS indicated TV commercials/advertisements have in fact been changed to the new 20 Day Review and will require an official review from CMS prior to use. With this change, TV commercials/advertisement cannot be used until CMS provides an Approval.
From CMS: We recently changed the review period for TV advertisements to 20 days. This was an internal decision. We are currently discussing communication strategies.
As of Wednesday 9/21, 10 days remain before marketing can occur. If you have TV commercials/advertisements you are planning to use and have not yet filed with CMS, please be aware of this change, as this can impact when your TV commercial/advertisement can be released.
We will share additional details as they become available from CMS. Please let us know if you have immediate questions.
Thank you
This is neither legal nor accounting advice. If you have questions, please consult a lawyer or accountant. The information included in this post was provided by the entity referenced herein.
