Among planners of physician-attended
pharmaceutical meetings in the United States, the PhRMA Code and
the Office of the Inspector General’s guidance on pharmaceutical
marketing are the twin tablets of the regulatory bible. The first,
from the Washington, D.C.-based Pharmaceutical Research and
Manufacturers of America, is the voluntary code of conduct that
keeps U.S. companies aboveboard when marketing to health-care
professionals, and the second is the mandatory and somewhat vague
set of government-imposed rules which, if broken, can result in
severe financial retribution.
For U.S.-based planners of such
meetings held abroad, American rules still apply -- while a set of
European authorities applies still more regulations. Although good
practices generally are the same everywhere, planners should know
how the guidelines differ, depending on where the meeting is
“If you’re already following the PhRMA
Code, you’re pretty good anyway,” says Judy Benaroche Johnson, CMP,
president and CEO of Rx Worldwide Meetings, based in Plano, Texas.
However, she adds, “Erring on the side of caution, it would be up
to me to know what the laws were, and to know what I could or
Following is a brief rundown of the
rules to know when holding pharmaceutical meetings in Europe.
The Geneva-based International
Federation of Pharmaceutical Manufacturers Associations (www.ifpma.org), to which
many national associations of pharmaceutical companies belong, put
into effect its revised global code of marketing conduct on Jan. 1
of this year. This document is meant to fill in holes in the
regulatory landscape: It will act as the voluntary code in
countries where regulations are not in place and will serve as a
baseline set of rules to follow for companies that do not belong to
a pharmaceutical manufacturers association. Though it’s very
similar to the PhRMA Code, here are some key points.
* The code states that all meetings for
health-care professionals should be meant either to provide
information to attendees (an educational meeting or speaker
training) or to get information from them (an investigator or
consultant meeting). Doctors should not be invited to meetings that
* No company can take a health-care
professional abroad unless there is a logistical or security reason
to do so. In other words, if a company is holding a meeting for
French doctors, the meeting must be held in France. A
pharmaceutical company cannot choose a location for doctors,
whether it has hired them or not, based on where they’ll want to
go. The same logic applies to resorts: “Renowned or extravagant
venues” cannot be chosen for meetings.
* All promotional material must be
explicit as to where the medication has been approved.
* Sponsorship of doctors’ attendance
can include only the attendees’ travel, meals, accommodation and
registration fees. Meals can be provided only for educational
* Entertainment must be secondary to
* When looking over the elements of the
program, every aspect should be seen as “moderate,” “modest” and
“reasonable.” Hospitality should not exceed what the recipients
would pay on their own.
* Gifts must be modest and relevant to
the health-care profession. Other inexpensive gifts may be given
“infrequently” on holidays.