Compliance: Obey and Avoid - Pharmaceutical Executive


Compliance: Obey and Avoid
Advice from a corporate compliance officer can keep the prosecutors away.

Pharma Meetings

3. Volume of business If your criteria for inviting people to a meeting is that they're high prescribers, it'll look like a quid pro quo. You're basically giving out quids for your high-volume prescribers. That's not to say that you wouldn't expect to see high-volume prescribers at a meeting, because obviously those are the physicians who are using that particular treatment the most and would have the most knowledge and experience. If you were looking at anti-psychotics, for example, and holding some kind of medical meeting around their use, you may not want to limit it to people directly prescribing your medicines. You may want to include physicians who prescribe some of your competitors' products. But even that needs to be looked at within the context of the entire meeting.

4. Modest location This comes out of the PhRMA Code. The idea here is that prosecutors, in particular federal prosecutors, have looked at meetings with customers and/or prescribers in high-end or exotic locations as being kickbacks. And so you want to stay away from hotels that have the word "resort" in them, for example. It would be better to be in the Hilton Miami than the Hilton Resort Miami, for example. You have to come at it from a practical perspective.

Ninety percent of this, as a general rule, is substance over form. That is, what is it you're actually doing at the particular hotel or convention center, not where are you doing it? But there is a small component of it that is form over substance, and so if you're going to be in a vacation type of place, like Hawaii, particularly if you're inviting a lot of people from the East Coast, that would seem a little excessive. If you were in Los Angeles, maybe that would be a little less excessive. But again, it depends on what you're doing and how you're doing it. And you have to keep the mindset that it has to appear modest. That doesn't mean that you should automatically remove Disney World from your list. It may be an appropriate venue for a meeting, but you have to look at what's actually happening in the meeting when you get everybody there. Are you spending more time in the park or more time at the meeting?

Whos Watching?
5. Entertainment second Again, the main purpose of the meeting should be the overall driver of the meeting. So if the meeting is designed to discuss a particular product, therapy or therapeutic class, then a majority of the time should be spent doing that. That doesn't mean that you have to get rid of all the entertainment or social aspects of the meeting, but they need to be subordinate to the main purpose. It shouldn't be that 55 percent of the time is spent discussing the topic, while socializing and entertainment takes up 45 percent of the time. You'd much prefer to see the topic comprise 70 to 80 percent of the time and the other 20 to 30 percent can be spent having fun. And again, be modest. You wouldn't expect to see the Rolling Stones at a meeting. But you could imagine somebody playing the piano at a cocktail party.


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