Transfers of Value – definition
The EFPIA Disclosure Code requires all member companies of EFPIA to disclose publicly all payments and other transfers of value made to Healthcare Practitioners and Healthcare Organisations (HCPs and HCOs) in certain categories.
The term ‘transfer of value’ is wider than just direct financial transactions – it includes indirect transfers too. See the full definition for details. The Australian Code is very similar to the EFPIA Code with respect to disclosure.
In the US payments made by pharmaceutical companies are governed by the ‘Anti-Kickback Statute’. The Anti-Kickback Statute prohibits offering, paying, soliciting or receiving remuneration to induce referrals of items or services covered by Medicare, Medicaid and other federally funded programs. The Anti-Kickback Statute is intended to ensure that a physician’s medical judgment is not compromised by improper financial incentives and is instead based on the best interests of the patient.
A direct or indirect transfer of value, whether in cash, in kind (i.e not cash), or otherwise made, whether for promotional purposes or otherwise, in connections with the development or sale of medicines.
A direct transfer is one made directly by a company for the benefit of a recipient.
An indirect transfer of value is one made on behalf of a company for the benefit of a recipient or through an intermediate and where the company knows or can identify the recipient that will benefit from the transfer of value.
