Undoubtedly in response to OIG's November 2020 Special Fraud Alert: Speaker Programs issued, on August 6, 2021, PhRMA issued a statement addressing an update to the PhRMA Code on Interactions with Health Care Professionals, which will become effective on January 1, 2022. PhRMA updated its principles applicable to company-sponsored speaker programs and clarified other provisions of the PhRMA Code in the following ways:
- Education: The updated PhRMA Code reiterates
that the purpose of a speaker program should be to present
substantive educational information designed to help address a bona
fide educational need among attendees, taking into account recent
substantive changes in relevant information or the importance of
the availability of such educational programming. Invitations to
speaker programs should be limited to those who have a bona fide
educational need for the information being presented.
- Meals: In addition to reiterating that meals
should be an incidental business courtesy to attendees of
company-sponsored speaker programs and modest as judged by local
standards, the updated PhRMA Code states that pharmaceutical
companies should not pay for or provide alcohol in connection with
speaker programs. The update also clarifies that high-end
restaurants and other such venues are not appropriate locations for
speaker programs.
- Attendance: The PhRMA Code states that repeat attendance at speaker programs that are substantially the same is generally not appropriate (unless an bona fide educational needs exists), attendance by speakers as participants at programs after speaking on the same or substantially the same topic is generally not appropriate, spouses or other guests should not attend company-sponsored informational presentations unless these individuals are health care professionals for whom the informational presentation is appropriate, and that attendance by friends, significant others, family members and other guests of a speaker or invited attendee is not appropriate (unless these individuals have an independent, bona fide educational need to receive the information presented).
The updated PhRMA Code on Interactions with Health Care Professionals, which becomes effective until Jan. 1, 2022, may be found here.
The current PhRMA Code on Interactions with Health Care Professionals, which is effective until Jan. 1, 2022, may be found here.
Compliance with the PhRMA Code on Interactions with Health Care Professionals is generally recognized as a base line for pharmaceutical compliance programs, and historically recognized by OIG as a means to substantially reduce the risk of fraud and abuse for pharmaceutical manufacturers and help demonstrate a good faith effort to comply with federal health care program requirements.
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