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ECPs can offer COVID-19 vaccine incentives, TGA says

Covid-19 Vaccine

Optometry Australia (OA) is urging caution for practices considering offering gifts or discounts to fully vaccinated patients as part of changes to advertising regulations to support the government’s COVID-19 vaccine rollout.

In recent weeks, the Therapeutic Goods Administration (TGA) updated rules around the lawful communication and promotion of COVID-19 vaccines and is now allowing businesses to offer incentives and rewards to people who have received two full doses.

Since vaccines became available in Australia in February, sections of the medical sector have been frustrated over strict promotional and advertising regulations that work to prevent drug companies from advertising prescription drugs directly to consumers. Some felt this has hampered vaccination efforts, with just 841,000 (3.3%) Australians fully vaccinated.

As part of the updated guidance, the TGA has advised any party, including health professionals, corporate entities and media outlets, can now create their own content to promote COVID-19 vaccines, provided this information is consistent with current Commonwealth health messaging. Any promotion must not reference brand names such as Pfizer or AstraZeneca or any active ingredients.

The rules prevent comparisons between different COVID-19 vaccines or statements that the vaccines cannot cause harm or have no side effects.

The TGA’s amended guidelines also allow health providers and other businesses to incentivise people to receive the COVID-19 vaccine by offering discounts, prizes and cash.

Compliant examples of COVID-19 vaccine incentives and promotional material. Source: TGA.

“While offers of a reward for being fully vaccinated are most likely to be provided by businesses who are not providing health services, it is possible that healthcare professionals such as GPs or pharmacists may also offer a reward,” the TGA said in a joint statement with the Australian Health Practitioner Regulation Agency (Ahpra).

“Importantly, the TGA’s guidance on promotion of COVID-19 vaccines does not change responsibilities that health practitioners and other advertisers have under the National Law when advertising a regulated health service. Both sets of regulations and guidance operate in parallel.”

According to the TGA, incentives can be offered with the following conditions:

  • It can only be made to people who have been fully vaccinated (two vaccinations). The TGA does not prescribe how full vaccination is to be verified.
  • 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 alcohol, tobacco or medicines (other than listed medicines).
  • The offer must only refer to COVID-19 vaccines generically (i.e. not by trade name or another reference to a particular vaccine, such as ‘the mRNA vaccine’).
  • The offer cannot be made to only those people vaccinated from the date of the offer, and must also apply retrospectively.

While it wasn’t immediately clear how or if optometry practices would take up the initiative, industry figures have suggested this could be done through vouchers, discounts on products such as eyewear, competitions or other inducements.

In a statement to Insight, OA said given the highly infectious nature of COVID-19, it strongly recommended all optometrists and practice staff to maintain the highest standard of PPE and infection control to protect both themselves and their patients.

“While we firmly endorse COVID-19 vaccinations as another layer of protection in the fight against coronavirus, the decision to incentivise optometry patients to have a vaccination is a decision that rests with each optometry practice,” OA stated.

“Where a practice decides to take this option, we would caution that the practice is following both the TGA’s guidance and advertising requirements of the national law.”

The TGA rule changes will remain in effect until December 2022.

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