Pharmaceutical CompaniesWhat is reported:
- Participation in congresses and events (limited to the participation fees, travel and accommodation)
- Consultancy services
- Donations and grants
- Research & development expenses
- Exclusions: transfers of value regarding over-the-counter (OTC) products, gifts of negligible value, samples, meals and accommodations
Medical Device Companies
What is reported:
CODE: The Members, individually for each recipient, shall disclose the amount of transfers of value made over the course of the previous year with reference to:
- Costs for participation in training, educational and promotional events on company’s products organised by the Members (excluding meals and beverages);
- Fees for consultancy activities and professional services, including speaking services, set forth in a specific contract between the Member and the professional indicating the type of service rendered, including the related travel and accommodation costs (excluding meals and beverages).
The Members must make public, on an individual basis, the amount of the transfers of value made with each healthcare organisation or other third parties by way of:
- Financial support of events (e.g. sponsorship of conventions, congresses and scientific meetings, etc.) aimed at meeting a scientific or other educational/training need as described in paragraphs 2.7.1 and 2.7.2 (excluded meals and beverages)
- Fees for consultancy activities and professional services, including speaking services, under a specific contract between the Member and the healthcare organisation, indicating the type of service rendered, including the related travel and accommodation costs (excluding meals and beverages);
- Donations in cash or cash equivalents provided to the HCO
The following transfers of value shall also be published in aggregate form:
- All donations in cash and cash equivalents to third parties, other than the HCO
- Costs for research and development activities
LAW: All payments to HCPs employed by NHS except in the following cases:
- Collaborations with journals, encyclopedias or similar publications
- Economic use of the HCP’s intellectual property
- Participation in seminars or conferences
- Whenever only the costs are reimbursed to the HCP
- When the performance of the services puts the HCP in “leave” from his/her position
- Assignments pursuant to a role or position in trade unions
- Training activities and training directed to employees of the public administration as well as scientific research
- This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
- Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information reflects that most recent changes and is still applicable.
- Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. (In such cases, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of that association).
- “Due date” means the date on which the transfers of value need to be published. For example, the deadline for submitting/sending the complete information to the authority could be before the due date to give HCPs/HCOs the opportunity to check the data that the pharmaceutical companies/medical device companies are going to disclose.
- The information does not take into consideration:
- Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
- Transparency related to patient organizations (unless the patient organization is considered an HCO)
- If your company is a member of MedTech/EFPIA (or if the industry association your company belongs to is a member of MedTech/EFPIA), the due dates are as mentioned above for MedTech/EFPIA (end of June), unless a law/regulation specifically states otherwise (e.g., the jurisdiction is suspended/exempted from following MedTech/EFPIA).
The information contained in this website is for general information purposes only. The information is provided by MediSpend and, while we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is, therefore, strictly at your own risk.
In no event will MediSpend be liable for any loss or damage including, without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.
Through this website you may be able to link to other websites which are not under the control of MediSpend. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.
Every effort is made to keep the website up and running smoothly. However, MediSpend takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.