Pharmaceutical companies’ representatives are the bridge between the pharma company and Healthcare Professionals (HCPs). Their direct interactions with HCPs must represent ethics, professionalism, and integrity. PhRMA code is an embodiment of the principles upon which relationships with HCPs are maintained by drug or medical device manufacturers within ethical limits.
In the world before COVID:
PhRMA code’s Section 2 originally outlined that in order to provide important scientific information and to respect health care professionals’ work-life balance, company representatives may present scientific and clinical information about medicines during health care professionals’ working hours.
This section also describes that it is appropriate to offer occasional meals as a business courtesy to the health care professionals as well as members of their staff attending company representative’s presentations but such meals should limited to in-office or in-hospital settings. Offering “take-out” meals or meals to be eaten by HCPs and their staff without a company representative present is not appropriate.
Post-COVID world:
COVID-19 pandemic has transformed almost every aspect of our lives and in-person interactions. How could pharma representatives and HCP interactions go unaffected?
This called for revision in PhRMA code’s section 2 also. Here are the revisions that have been made for such turbulent times:
“Presence” can be Virtual “Presence” of the Representative
Company representative’s presence was a requirement but due to COVID, this requirement has been given relaxation.
Informational presentations can now be given remotely over video or audio conferencing with delivery of a modest meal to HCPs and members of their staff, under Section 2 of the PhRMA Code, if following conditions are met:
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The representative is virtually “present” over video or audio conference throughout the event.
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Only if the HCP is expected to remain present throughout the event, a meal should be provided.
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“Take-out” meals and “dine & dash” programs are not appropriate.
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Any meal offered should be compliant to the provisions of Section 2 of the PhRMA Code, i.e that the meal should be modest according to local standards, provided so that is conducive to informational communication, limited to an in-office or in-hospital setting, and not extended to healthcare professional’s spouse or other guest.
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Meals should not be provided where prohibited by the policies of the HCP office or healthcare facility.
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Due to COVID contagion, companies are advised to consider healthcare facility policies regarding utilization of contactless delivery, food handling, and limitations on meal sharing.
Meals Limitation to “In-Office or In-Hospital” Settings Requirement Unchanged
Meals, as a business courtesy to healthcare professionals as well as members of their staff attending company representative’s presentations, should limited to in-office or in-hospital settings. Even in emergency situations such as the COVID-19 pandemic, meals would continue to be limited to these settings.
Under the PhRMA Code, informational presentations without a meal provided by the representative are not limited to such settings and can be offered outside of a hospital or office setting, given that the location is conducive to informational communication.
No restriction in the PhRMA Code whether such presentations occur in-person or virtually over video or audio conference.
Effective Period
The guidance set forth by the PhRMA code is to be applied during any national public health emergency period, as declared by the Secretary of Health and Human Services under section 319 of the Public Health Service Act (42 U.S.C. § 247d), or any applicable state or local declaration of emergency that results in restricted physical access to an HCP’s office.
This PhRMA Code document is not intended to replace or supersede applicable federal or state laws, which may also apply.
