In the past, we’ve looked at data collection for event attendees to help event planners and pharmaceutical companies better understand how to improve meetings, but that’s only half the picture. There’s a lot of data collection happening at corporate events, but even more when it comes to pharma events.
In addition to attendee data collection, pharmaceutical events must also collect data related to HCPs, including any payments (such as consulting fees or honoraria) or any goods that mark a transfer of value (such as travel, food and beverages, lodging, and more). However, the Sunshine Act and Open Payments are only part of the picture. Understanding PhRMA and EFPIA is vital, as that’s where the nuances and variations that can make data collection more complex live.
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The Sunshine Act requires that pharmaceutical manufacturers, among others, collect detailed information about any payments or other transfers of value for goods or services made to HCPs or teaching hospitals/universities. Accompanying the Sunshine Act is the Open Payments program, which takes that reported data and shares it publicly via a website. The combined goal of both of these is to increase and improve transparency. Presumably, patients would then be better able to understand the connections and relationships between their care team and pharmaceutical/medical device and supply companies.
Currently, reporting organizations submit their information annually to the Centers for Medicare & Medicaid Services (CMS) where the data is then published yearly, as well as reported to Congress. While Open Payments and the Sunshine Act dictate what must be reported, to whom, and when, they do not clarify what constitutes excessive payment or at what dollar value relationships appear to cross an ethical line. So prior to collecting HCP data at a pharmaceutical event, event planners and hosts must also be familiar with the acts that outline HCP compliance.
While the federal Sunshine Act and Open Payments collect and publish information about payments made to HCPs, they do not dictate or set acceptable payment or TOV amounts. Instead, those amounts are determined by the pharmaceutical companies based on what they feel comfortable providing and whether the goods, services, or amounts don’t appear to influence relationships.
So who determines the level of influence? How is ethical behavior defined when it comes to payments or transfers of value in the pharma space? That’s where both the PhRMA Code and EFPIA come in.
The ethics of payments in the pharmaceutical industry are based on those two distinct codes: one for the United States, the PhRMA Code on Interactions with Healthcare Professionals, and a corresponding European code, the European Federation of Pharmaceutical Industries and Associations (EFPIA).
It’s important to note that neither of these codes is mandated (meaning a pharma company may opt to exceed recommended spending), but individual states – including California, Nevada, Massachusetts, Connecticut, and the District of Columbia – have adopted or incorporated the PhRMA Code into their statutes or regulations.
Further, when it comes to programs held outside the United States, typically the “host country principle” applies. This means guidance is determined by the country hosting the program (if HCPs are attending from various countries). In other words, not only is it essential to understand who your pharma event HCPs are, but it’s equally important to know where they come from.
Because in most states there is no statute that determines what a pharmaceutical company can spend, ensuring that you’re working with venues and vendors that can accommodate HCP needs (as well as record accurate data) is essential to the pharma event space.
For most pharmaceutical companies, there is only an industry-level guideline providing an ethical framework. Due to this, the primary goal becomes to avoid payments or TOVs that are not only disallowed (such as inviting guests or entertainment), but those that appear to be too extravagant and may be viewed as an effort to curry favor.
As noted above, the data you are collecting for HCPs is legally mandated to be reported, so understanding some of the best practices to ensure you and your pharma client are in compliance is essential.
1. Confirm spending limits with the client
As noted above, with a few exceptions, spending limits are still determined by the client. Prior to any vendor or venue sourcing, you’ll want to have a good understanding of what they are comfortable spending for HCP travel, lodging, dinner, and any other goods or services they’ll need for the pharma event.
2. Determine the number and residency of HCPs
When it comes to tracking and recording the data you need, you’ll need to know where HCPs are coming from in order to adhere to any applicable state laws.
3. Choose the right tech tools
There’s a large market for event tech tools, but when it comes to collecting data for pharmaceutical meetings and events, the right technology will make all the difference. Not only do you want something that's capable of tracking the data you need, but you want something that’s reliable and allows you to easily pass the data on to the individuals or organizations that need it for reporting. For example, Cvent’s OnArrival platform is an excellent tool to track attendance and participation for compliance reasons.
4. Work with an event planner with pharma experience
While most event planning companies are capable of collecting attendee data, HCP data is a different beast – as are pharmaceutical events. Because you’re dealing with data that must be accurate and reliable (as it’s reported to government agencies and is reviewed by both industry leaders and consumers alike), omissions, mistakes, and miscalculations can be costly in terms of both finances and reputation. It’s just not worth the risk.
An event planning company with pharma event experience will be accustomed to handling attendees and HCPs, as well as planning an event that engages all guests, even with potential limitations. Further, an experienced event planner will be able to leverage venue and vendor relationships to maximize what you can offer your HCPs while staying compliant.
Bishop-McCann has nearly three decades of pharmaceutical industry experience and is well-versed in the needs of this niche. From managing the HCP experience to recording, tracking, and reporting HCP data, we’re ready to help you provide an unforgettable experience for all parties involved while ensuring you stay compliant.
Ready to talk about your next pharma event? Reach out to our team, and let’s get started!