Code of Conduct - Question & Answers
7b. Hospitality
- February 2005
Question 1:
We have been trying hard to keep up with the spirit
and the intent of the CODE, however here is one example of
Mudlarks Golf tournament. You will have to read the message
from company x below to get to the depth of the issue.
Please let me know what you think as our company is not comfortable
with our reps participating in this tournament. I somehow
do not agree with the interpretation of the Rx&D CODE
made by this company x Rep.
Looking forward to hearing from you.
Hello PRA Members!
YOUR REPLY AND PARTICIPATION IS NEEDED RIGHT NOW! PLEASE PLEASE
PLEASE let me know if you can play in this tournament AND
SEND IN YOUR REGISTRATION AND CHEQUE RIGHT NOW. ALSO SEND
ME AN E-MAIL TELLING ME IF YOU CAN OR CANNOT PARTICIPATE.
I have attached the Mudlarks invitation in a PDF file; please
print it off, show and share it with MD's that might like
to play and let's make this tournament happen, just like it
has for the last 41 consecutive years.
RE: Rx&D,
I know that this is a very challenging issue for all of us.
Bear in mind these points:
- We are asking everyone to pay their own way. Thus, we
are not "paying for access".
- In tournament format, it is suggested by Rx & D that
as long as foursomes are not organized the by the golfers,
it will not be "perceived as paying for access".
Please note that our organizer, Mr. Mike Ryan, is a retired
drug rep and is responsible for putting the groups together.
He will do his best to make everyone happy, and has always
done a very good job of it. You may enter as a single or
as a foursome within your company/other companies. The draws
will be made up once all registrations are in.
- Feel free to check with your own company to ensure that
you are following all rules. I do know that some companies
will not allow any golf under any circumstances. If this
applies to you (Novartis, I know you are one), please reply
directly to me so that I know what's going on.
- Doctors have all received a letter from Rx & D telling
them about these changes. They know that they have to pay.
I didn't say that they would all like it, but they are well
aware and most are will to accept it.
- It doesn't look like the Academy of Medicine tournament
will take place this year. No one stepped forward to take
it over from Dr. Butchey and Dr. Komar. Let's encourage
our golfing doctors, including those that consider themselves
as beginner golfers, to participate in Mudlarks with their
colleagues.
please please please REPLY TO THIS MESSAGE, AND GET YOUR
REGISTRATIONS IN. WE ARE UNDER A VERY TIGHT DEADLINE OF
EARLY NEXT WEEK. SHOULD THE TOURNAMENT NOT TAKE PLACE, (and
we desperately do NOT want that to happen), cheques will
be returned.
Response:
There is no problem in HPC and Industry representative in
participating in various social activities as long as every
participant personally pays its own expenses. Rx&D's
perspective on this issue is to prevent ‘' paying
for access ' and the perception that industry is offering
a gift to the HPC.
It is inappropriate for companies to reimburse representative
involvement in any non-Rx&D approved hospitality events.
Relevant Code Sections:
6.1.2 Where companies provide financial support to a charity
and/or non profit organization through such avenues as the
purchase of a table or tables at a dinner or other social
event, or through the purchase of a foursome or foursomes
at a golf tournament, or similar activity, individuals invited
to sit at the corporate table(s), or to play golf as part
of the foursomes, should not be healthcare professionals.
7b.1.2 During interactions with healthcare professionals,
companies may provide to participants only refreshments/meals
that are modest in content and cost. In all instances, the
provision of refreshments/meals must be clearly incidental.
No other form of hospitality or entertainment is to be provided.
Question 2:
- There are times where depending on the complexity of
the drug or the disease state, it is identified that certain
HCP would benefit from a training session (i.e. how to manage
a specific disease state or how to administer a specific
drug). Based on our interpretation of the Code and past
exchanges with members of the MPRC, we've determined that
training sessions are not regulated by the Code - correct?
Based on this assumption, we have however followed the spirit
of the Code in establishing allowable parameters which these
sessions must respect.
- Have you any guidance on what can be categorized as a
training session?
- or the required parameters?
Response:
This is in effect promotion and thereby should be done in
accordance with PAAB and Rx&D Code policy for hospitality,
etc.
Question 3:
It is not uncommon for sales representatives to provide lunch
for HCP in the interest of spending time with them during
their "lunch hour" and engaging in acceptable sales
rep: HCP exchanges. These types of interactions are often
termed lunch 'n learn as the HCP may at times request that
members of their staff attend so that they too may benefit
from the information being provided by the sales rep. Having
said this, the issue now lies with regards to the meal often
being provided by the sales rep and often upon the HCP's request.
It has been said that some HCP will explicitly ask that coffee,
dessert or lunch be provided in sufficient quantity so that
the staff may also participate. The HCP staff may include
nurses and technicians however it may also include clerical
or administrative staff. Assuming that all the staff in question
is participating in the exchange - is it acceptable to provide
sufficient food/beverages for all the participants?
What is Rx&D's position on this? How should the rep respond
to such a request from the HCP?
Response:
It is appropriate to do lunch and learns for a HCP. Providing
a modest lunch in return for an educational lunch and learn
is appropriate. You should avoid the "feed my staff"
for access ploy though, hence the requirement that the majority
of people in attendance have a patient care or education role.
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