As this sounds like a specific example, we suggest submitting for an opinion. As a generally guiding principle, if the unbranded promotional piece is for a branded patient campaign, it should be reviewed in the context of the brand, regardless of whether or not the brand is mentioned within the rep directed piece or not. The thought process behind this is that if you link branded and unbranded content, all content becomes branded and therefore requires review in the context of the brand.
If the program or unbranded campaign speak to “treatment” in any way (even without direct mention of a product), it would fall under the purview of the PAAB code and be subject to review.
If the program is unbranded, the piece is unbranded, and there is no mention or implication of “treatment” in either, it is possible that the piece is exempt from PAAB review.