Data Disclosure Rules
The PDRP disclosure rules specifically target first-line managers and sales reps, while everyone else in the company maintains
full access to the prescribing data as if PDRP did not exist. If the company is receiving data with PDRP recipients flagged,
the company must be able to generate PDRP-compliant versions of the information before it is distributed to first-line managers
or sales reps.
When physicians enroll in PDRP, the program limits first-line managers or sales reps from viewing their prescription data
to the following:
- Reps and direct managers can view the physician's prescribing volume quantiled at the therapeutic class level.
- They can view aggregated data (territory or specialty rollups, for example) or segmented data (categories into which the prescriber
falls, such as an early-adopter of drugs, for example) as long as this is not likely to reveal blocked data. Aggregated or
segmented data is used to provide messaging and direction in the field by grouping similar physicians using qualitative and
quantitative measurements.
- Reps and their direct supervisors are not allowed to access individual doctors' prescription counts, prescription volume,
projected prescription volume, prescription dollar volumes, prescription market share, product quantile, prescription percent,
or any type of change indicators (e.g., color coding, up/down arrows, and directional indicators, such as alerts).
Paramount to complying with PDRP's disclosure rules: Reverse engineering of blocked data is strictly prohibited. For instance,
if a first-line manager or sales representative cross-indexed an incentive compensation report with a physician target report
(unless they are both PDRP compliant), it might be possible to determine an individual physician's actual prescribing volume
or infer an increase or decrease. Or they might use a territory performance report with a physician target list.
As these examples illustrate, the reverse engineering requirement is difficult to implement without the use of advanced technology.
PDRP requires companies to censor prescription data, as previously described, to observe the physician's desire to have his
prescribing data restricted. But it does not require the removal of all physician prescribing data from systems used by first-line
managers or sales reps.
Achieving full compliance while using the maximum level of individual prescriber data permitted by PDRP may pose a greater
technology challenge than most organizations will have determined.
Organizational Impact
The use of physician prescribing data has become so ingrained within sales and marketing that the impact of PDRP compliance
will be widespread. Computer systems, business strategies, standard operating procedures, and policies are all affected.
When assessing readiness, pharmaceutical companies may need to reconsider vast sales-support technologies that integrate prescriber
data, including incentive compensation, sales reporting (including dashboards and alerts), ad hoc reporting (especially distribution
to first-line managers and sales reps), physician targeting and pull through, sales force automation, customer segmentation
indicators, marketing messages, detailing and sampling, standard operating procedures and polices, sales training, contract
sales, and human resources.
A compliance strategy that doesn't consider all of these elements is incomplete and may expose a company to potential compliance
violations.
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