Key Topic 1: Clear Educational Content
You should consider the educational content of each meeting in terms of its quality and relevance, but also on the total proportion of the meeting time that involves educational content.
The quality of the educational content should be the aspect that attracts delegates to attend. It should also be of relevance to the target audience.
Consider also the balance between the time spent on educational content and the time spent on hospitality – this is often a matter of judgment depending on local regulations.
However generally time spent on hospitality and socializing should never exceed the time spent on the educational content.
The following examples show how some companies have got this judgment right and wrong in the past:
Example 1
In Australia the Medicines Australia Monitoring Committee review educational events conducted by pharmaceutical companies. As part of this review they asked for an event conducted by Amgen to be investigated.
Amgen had invited 14 health professionals who were delegates at the American Society of Nephrology (ASN) meeting in Atlanta to a tour of the company manufacturing facility in Puerto Rico.
Those invited were “opinion leaders in the nephrology community” who not only prescribed medicines for their patients but also were in influential positions as members of hospital or state formulary committees.
The event included 2 nights accommodation and 2 dinners. During the event presentations were given which provided clinical information about erythropoietin and the treatment of anaemia associated with chronic kidney disease and biosimilar medicines. Amgen marketed the product Aranesp. The cost of the meeting was just over $46,000.
Amgen stated that the meeting was organised because healthcare professionals needed to be assured through first-hand experience of a manufacturing facility that biologic medicines met appropriate quality standards.
Which of the following do you agree with?
- These presentations could have been given in Atlanta therefore the purpose of the meeting in Puerto Rico is not acceptable
- The hospitality is out of proportion to the educational content
- $46,000 for 14 health professionals is excessive
- This meeting would not stand up to public scrutiny
- The reason for this meeting is unconvincing
Ruling
The Committee found this event to be in breach of the Australian Code. They were ‘very concerned that the primary purpose of the meeting was to influence individual healthcare professionals to prescribe Aranesp and more broadly to influence key decision makers who are members of hospital formulary committees. They considered that the primary purpose of the presentations and the plant tour were to persuade the attending healthcare professionals to continue to prescribe and recommend Aranesp rather than any biosimilar product. In conclusion the educational content would not stand up to public scrutiny. However the travel and accommodation provided was appropriate.
Amgen were fined $200,000.
Interestingly this ruling was overturned on Appeal. In terms of educational content the majority of the Appeals Committee accepted that it was beneficial for specialist physicians to be educated about these complex molecules and the differences between biologics and small molecule medicines.
In addition the majority of the Committee accepted that it was reasonable to hold the educational meeting at the Puerto Rico plant following the ASN meeting in Atlanta, as the delegates were in relatively close proximity.
This case demonstrates that these matters are often a matter of judgement.
Example 2
In the UK an anonymous complainant provided some photographs which were said to show a Merck Sharp & Dohme sales representative entertaining a group of doctors and their wives at a Chinese restaurant. The complainant alleged that the meeting had no educational content and was held in the public domain.
The Panel examined the restaurant receipts and found the costs to be acceptable. However there was no written invitation, no agenda and little other information.
The meeting did not have a sufficiently clear educational content to justify the provision of hospitality. The meeting had been held on a Friday night in a part of a restaurant where the public were also present.
The venue was therefore deemed unsuitable. The representative had not maintained a high standard of ethical conduct. The Panel considered that the arrangements for the meeting were totally unacceptable.
MSD was found to have brought discredit upon the industry.
The Panel examined the restaurant receipts and found the costs to be acceptable. However there was no written invitation, no agenda and little other information. The meeting did not have a sufficiently clear educational content to justify the provision of hospitality. The meeting had been held on a Friday night in a part of a restaurant where the public were also present. The venue was therefore deemed unsuitable. The representative had not maintained a high standard of ethical conduct. The Panel considered that the arrangements for the meeting were totally unacceptable. MSD was found to have brought discredit upon the industry.
This example illustrates the importance of documentation, the need for clear educational content, acceptability of venue and the general ‘impression’ created which the Panel said was “a mainly social event on a Friday night paid for by the pharmaceutical industry.”
Example 3
A nurse in the UK complained about arrangements for an educational meeting about aesthetics organised by Galderma (UK) in association with a nurse support group.
The complainant provided the agenda which listed four presentations, two of which were particularly relevant to medicines marketed by Galderma; one was about botulinum toxins (Galderma marketed Azzalure) and the second was about the company’s product Pliaglis (tetracaine/lidocaine), a topical anaesthetic for use in dermatological procedures.
The covering letter sent with the agenda stated that there was no meeting charge for members of the nurse support group but ‘due to the high calibre of the speakers provided by Galderma you are required to have purchased a minimum of Two Emervel Classics (dermal fillers) from [named pharmacy] between now and the 16th November 2013’.
An email also sent with the agenda stated that there was no charge for the meeting but certain purchases were required. The covering letter further stated that ‘[named pharmacy] have kindly confirmed a special offer price for us all of £74.34 per box. You will also receive a free Restylane Skin Booster and complimentaries on the day. For a cost of £150 we get a fabulous deal, equivalent to £240 worth of products plus the meeting’.
Delegates had to bring their invoices to the conference as proof of purchase to gain entry. Attendees who were not members of the nurse support group were charged £40 to attend and were also required to purchase 2 packs from the named pharmacy.
Which of the following do you agree with?
- This meeting does not appear to be primarily educational the condition that purchases of particular products have to be made to gain entry to the meeting raises doubts about its primary purpose
- This is a promotional meeting there are presentations about botulinum toxins including Galderma’s products
- The content of the meeting must stay within Galderma’s product labels
- The impression of the meeting makes it unapprovable
Ruling
The Panel considered that the discount offered on the obligatory purchase of Emervel together with the items received on the day meant that attendees were given a pecuniary advantage of a minimum of £90 in connection with the promotion of Azzalure and Pliaglis and a breach of the Code was ruled.
