The EFPIA Disclosure Code goes live: what does it all mean?

Changes came into effect at the end of June transforming the way pharmaceutical companies in Europe work with healthcare professionals (HCPs) and healthcare organisations (HCOs).

The European Federation of Pharmaceutical Industries and Associations (EFPIA) has introduced a new disclosure code, requiring companies to disclosure any transfers of value (whether in cash, in kind or otherwise) provided to HCPs and HCOs.

Partnerships between the pharma industry, and HCPs/HCOs is arguably vital in helping to bring new medicines to market. The new obligations aim to provide greater transparency and dialogue on the ethics behind payments made by pharma to doctors.

In the UK, payments are disclosed on the Association of the British Pharmaceutical Industry’s (ABPI) publically available database Disclosure? UK, which so far details all payments made in the 2015 calendar year.

What does Disclosure UK reveal?

The database shows payments from 109 pharmaceutical companies, revealing £340.3 million paid to support activities ranging from:

• Research and development
• Service and consultancy work
• Registration fees and associated travel and accommodation expenses
• Contribution for events
• Donation and grants
• Joint working arrangements with the NHS

What does this mean?

As the new code (quietly) came into force last month, many companies are suddenly faced with the reality of meeting minimum transparency requirements. A couple of points for companies to consider:

• Have internal processes been put in place to ensure transfers of value are collected correctly?
• Are employees (and third party consultants) across the organisation familiar with these internal processes?
• Have legal contracts been updated to include the necessary consent to disclose?
• What is the company’s position if consent to disclose payment of value is not secured by the HCP or HCO?

There is also the consideration of public trust with the industry and individual doctors – as even the perception of a conflict of interest could have damaging effects. Whether this happens is yet to be seen – much of this will depend on if we see a small drip-feed of payment related articles over the summer.

It is going to take years of PR and communication (internal and external) so the public and media does not misinterpret legitimate payments to HCPs and HCOs from pharma companies – and understand the importance of such partnerships.