Similarly, what is not widely known is that the pharmaceutical industry's commercial interest in the data ultimately makes
possible a variety of other research applications. The industry underwrites the substantial costs that HIOs incur when collecting
and processing the information. Without this support, the data would not exist for use in:
- Evidence-based drug safety studies
- Public health monitoring to set and promote public health policy
- Outcome studies and pharmacoeconomic analyses that look at value vs. cost
- Bioterrorism surveillance
- Development of clinical practice guidelines
- Disease management programs
- Analysis of changes in government healthcare programs (e.g., the uptake of Medicare Part D coverage).
In general, prescribing data accelerates healthcare innovation and ultimately enables patients and providers to make better
healthcare decisions. One of the hottest healthcare initiatives at the federal level is a push toward greater transparency
of current healthcare practices. The public needs to be able to track and identify the quality of care and efficiency of practitioners.
Banning access to prescriber information could reduce the benefits to consumers. Providing prescriber information to researchers,
teaching hospitals, and diseases advocacy groups also helps consumers gain access to information about services, quality,
and price within the healthcare market. Physicians and consumers alike are empowered to improve their healthcare decision
Physicians will have to choose whether to enroll in PDRP. The industry and HIOs can help by educating them on the broader
implications of that decision.
Advice for Pharmacos
First and foremost, it is important for the industry that individual pharmaceutical companies comply in letter and spirit
with the requirements of the PDRP. Companies that interpret their data-use contracts too narrowly will sabotage the success
of the program and pave the way for legislation that imposes stricter measures on the industry. Such legislation, which would
ban the use of prescribing data for marketing and other commercial purposes, has been introduced in six states, but the prospect
of PDRP has stalled it in four.
As it stands today, the PDRP still allows the industry to use prescribing data to make critical business decisions in marketing
and sales management. The PDRP restricts only data about physicians who enroll in the program. The industry will be best served
if each pharmaceutical company adopts a company-wide strategy to ensure that it respects physicians' wishes—rather than simply
implementing a technical plan to manipulate data according to a contractual obligation.
Each pharmaceutical licensee should:
- Adjust processes to receive and implement the list of participating physicians.
- Install programs to restrict prescribing data on PDRP enrollees in field-force deliverables.
- Review reports with roll-up capabilities and determine the appropriate business rules.
Sales operations should:
- Have quality controls in place to ensure that reports to the field are compliant.
- Prepare reps for the changes they will see in their field reports.
Sales departments should:
- Retrain all sales representatives and sales operations personnel on the responsible handling of physician prescribing information.
Disclosure of this information to anyone outside of the company is a violation of the HIO contract.
- Sales representatives must be cautioned against displaying or discussing prescribing data with physicians. Reps should use
it for background purposes only—regardless of a physician's PDRP status. They must understand that, from the physician's perspective,
"prescribing data are personal and sensitive in nature," as laid out in the AMA Best Practice Guidelines of 2001. It is absolutely
inappropriate to use prescribing data to accuse, coerce, badger, or otherwise pressure a physician to prescribe a particular
- Inform sales representatives that they must never "reverse engineer" or re-identify any prescribing information of a PDRP
- Train sales managers to support the nature and intent of the PDRP.
- Clarify the consequences for abuse and enforce applicable codes of conduct.
- Communicate the larger picture and explain what is at stake if the AMA PDRP fails.