The Prescription Medicines Code of Practice Authority (PMCPA) publishes relevant case studies to act as guidance for all those who are involved in the planning and organisation of pharma meetings and events plus other useful advice re the use of meetings to promote pharmaceutical products and services.
Here is some recent advice issued by the PMCPA that is relevant to pharma meetings
1. Meeting Venues
Companies are reminded that when organising meetings which are subject to the Code, they must ensure, inter alia, that the venue is appropriate and conducive to the main purpose of the meeting. Responsibility in this regard should not be delegated to a third party.
It follows that venues must be approved on a case by case basis according to the type of meeting to be held and the target audience. For example a venue which is suitable for a two day meeting of international thought leaders might not be suitable for an evening meeting of local GPs. Similarly, successful use of a venue does not guarantee its suitability for future meetings. Venues can change over time with regard to the facilities and/or level of hospitality offered.
2. Sport and Leisure Venues for Meetings?
The supplementary information to Clause 19.1 of the Code, Meetings and Hospitality, states, inter alia, that venues for meetings must be appropriate and conducive to the main purpose of the meeting; lavish and deluxe venues must not be used and companies should avoid using venues that are renowned for their entertainment facilities. The impression that is created by the arrangements for any meeting must always be kept in mind. Meetings organised for groups of doctors, other health professionals and/or appropriate administrative staff which are wholly or mainly of a social or sporting nature are unacceptable.
When large numbers of delegates are to be invited to a meeting it may be impossible to hold it at a business style hotel. A conference centre within a football stadium or the like may have to be used instead. Companies organising, or sponsoring, meetings at such high profile venues should be satisfied that no other venue is large enough to accommodate the meeting and that the overall impression given by the proposed arrangements would not be unacceptable in relation to the requirements of Clause 19.1. Gratuitous use of sporting or leisure venues is unacceptable. It must be the programme that attracts delegates to a meeting, not the venue. Further, companies must ensure that no sporting events take place at the venue immediately before, during or immediately after the meeting. Venues must not be used so as to knowingly take advantage of any entertainment/sport that has been organised/subsidised by a third party
3. Advice on Advisory Boards
It is acceptable for companies to arrange advisory board meetings and the like and to pay health professionals and others for advice on subjects relevant to their products. Nonetheless the arrangements for such meetings have to comply with the Code.
As with promotional meetings, the requirement that hospitality be of an appropriate standard, as set out in Clause 19 of the Code, has to be followed. The meeting should be held in an appropriate venue conducive to the purpose of the meeting.
To be considered a legitimate advisory board the choice and number of participants should stand up to independent scrutiny; each should be chosen according to their expertise such that they will be able to contribute meaningfully to the purpose and expected outcomes of the meeting. The number of participants at a meeting should be limited so as to allow active participation by all. The agenda should allow adequate time for discussion. The number of meetings and the number of participants at each should be driven by need and not the invitees’ willingness to attend. Invitations to participate in an advisory board meeting should state the purpose of the meeting, the expected advisory role and the amount of work to be undertaken.
If an honorarium is offered it should be made clear that it is a payment for such work and advice. Honoraria must be commensurate with the time and effort involved and the professional status of the recipients.
4. Make it Formal
Companies are requested to remind all employees that when they plan a meeting for health professionals and appropriate administrative staff at outside venues, hospitality must be secondary to the purpose of the meeting. To ensure that the meeting has a clear educational content organisers would be well advised to draw up, in advance, a formal agenda detailing the subjects to be discussed, together with timings where appropriate, and issue that as part of the invitation to the meeting. Invitations should be carefully worded so that delegates are attracted by the programme and not the associated hospitality or venue. The venue should be suitable for the purpose; the Code of Practice Panel is likely to rule any educational meeting held in an area of a restaurant, which at the same time is open to members of the public, in breach of the Code. A useful criterion in determining whether the arrangements for any meeting are acceptable is to ask ‘Would I and my company be willing to have these arrangements generally known?’. The impression that is created by the arrangements for any meeting can be as important in determining its acceptability under the Code as the arrangements themselves. Companies are reminded that they risk being ruled in breach of Clause 2 of the Code in relation to meetings where the hospitality is out of proportion to the occasion and/or the educational content is slim.
5. Use of Third Parties to Organise Meetings
The Code of Practice Panel has considered a small number of cases where representatives have delegated some of the responsibility for organising a meeting to a third party. Companies should remind representatives that in such circumstances the representative nonetheless remains responsible for all aspects of the meeting and the company remains liable for it under the Code. It is beholden upon representatives to ensure that any third party to whom they entrust any aspect of organisation of a meeting is fully conversant with the relevant requirements of the Code. Such requirements extend beyond Clause 19, for example posters advertising a meeting must not unwittingly be turned into promotional material by someone unfamiliar with the Code. The first priority of a representative in organising a meeting is to ensure it complies with the Code regardless of the offers of help or arrangements made by others. Responsibility for compliance cannot be delegated to third parties.