Article
Recent revisions to the PhRMA Code on Interactions with Health Care Professionals regarding speaker programs
Aug. 23, 2021 · Authored by Samantha Brabant, Ashley Jones
The Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Health Care Professionals (PhRMA Code) is a voluntary code of ethics that applies to pharmaceutical company interactions with healthcare professionals (HCPs) in the U.S. Three revisions have been made to the PhRMA Code since it was originally published in 2002, including a revision, which is effective Jan. 1, 2022.
The most recent update revises the PhRMA Code’s guidance on speaker programs in response to the Office of Inspector General’s (OIG) Special Fraud Alert on Speaker Programs, which was issued in November 2020.
The PhRMA Code revises three principles of speaker programs sponsored by the pharmaceutical industry:
- the purpose of speaker programs
- meals and modest venues
- speaker program attendance
Purpose of speaker programs
The updated PhRMA Code strengthens the message that the purpose of speaker programs is to present “substantive educational informational designed to help address a bona fide educational need among attendees.” Accordingly:
- Bona fide educational need should take into account substantive changes to relevant information, such as new medical or scientific information, or a new U.S. Food and Drug Administration (FDA) approved indication for the product
- Invitations for speaker programs should be limited to individuals who have a bona fide educational need for the information, which is the subject of the speaker program
Meals and modest venues
It’s been PhRMA’s long-standing position that meals provided to speaker program attendees should be modest, as per local standards. In addition, the revision to the PhRMA Code states that pharmaceutical companies should not pay for or provide alcohol in connection with speaker programs and clarifies that “high-end restaurants,” and other such venues, are not appropriate locations for speaker programs.
Speaker program attendance
The recent revision to the PhRMA Code provides additional guidance on HCP attendance at speaker programs. The revised PhRMA Code states the following are generally not permissible in regard to speaker program attendance: