Pharmaceutical Transparency Requirements

As we approach the deadline for pharmaceutical companies to begin capturing information regarding their “Transfers of Value” to Healthcare Professionals and Healthcare Organisations, some companies are struggling to implement consistent data capture processes across their European affiliates.

The EFPIA Disclosure Code has now been transposed into national industry body codes in most countries within EFPIA’s scope.  However, a few countries have yet to fully embrace the EFPIA Disclosure Code, leaving Compliance & Ethics Officers in those countries, and their European leaders, with a difficult dilemma regarding how to comply with both the EFPIA requirements and local requirements.

Some countries (e.g. France, Portugal) already have onerous disclosure requirements that are enshrined in national laws rather than industry body codes, meaning that they apply to all companies regardless of whether or not they have joined their national industry association.  Reporting is already underway in most of these countries with potential criminal sanctions for those companies that get it wrong.

In contrast, those countries that do not have national laws to comply with need to begin data collection from 1st January 2015 for reporting by end June 2016.  If your company has not yet begun to put processes and tools in place to capture these “Transfers of Value”, time is running out for proactive data collection (which will be much easier than retrospective data collection).  Contact us if you need help to get you started.