The PhRMA Code on Interactions with Health Care Professionals (“PhRMA Code”) is a voluntary code of ethics that applies to pharmaceutical company interactions with U.S. health care professionals. The PhRMA Code reinforces PhRMA’s intention that pharmaceutical company interactions with health care professionals follow the highest ethical standards and applicable legal requirements. Signatory companies, which include both PhRMA members and non-members, submit annual certifications to PhRMA certifying that the companies have policies and procedures in place to foster compliance with the PhRMA Code.
Originally published in 2002, the PhRMA Code was updated in 2009 and again in 2019 as part of an ongoing commitment to ensuring that pharmaceutical company interactions comply with the highest ethical standards. In the revisions it is announcing today, PhRMA has updated its principles applicable to company-sponsored speaker programs and clarified other provisions of the PhRMA Code.
- Purpose: The PhRMA Code has long recognized that company-sponsored speaker programs provide important substantive educational information about the benefits, risks and appropriate uses of company medicines and related disease states. Building on this fundamental principle, the PhRMA Code now reiterates that the purpose of a speaker program should be to present substantive educational information designed to help address a bona fide educational need among attendees, taking into account recent substantive changes in relevant information (e.g., new medical or scientific information or a new FDA-approved indication for the product) or the importance of the availability of such educational programming. Invitations to speaker programs should be limited to those who have a bona fide educational need for the information presented at the program.
- Incidental meals and modest venues: The PhRMA Code has long emphasized that meals offered as an incidental business courtesy to attendees of company-sponsored speaker programs should be modest as judged by local standards. The updated PhRMA Code reiterates this point and states that pharmaceutical companies should not pay for or provide alcohol in connection with speaker programs. The updated PhRMA Code also clarifies that high-end restaurants and other such venues are not appropriate locations for speaker programs.
- Attendance: The updated PhRMA Code clarifies various principles related to attendance at speaker programs. The PhRMA Code now states that repeat attendance at a speaker program on the same or substantially the same topic where a meal is provided to the attendee is generally not appropriate, unless the attendee has a bona fide educational need to receive the information presented. Furthermore, the PhRMA Code clarifies that attendance by speakers as participants at programs after speaking on the same or substantially the same topic is generally not appropriate. Finally, the PhRMA Code has long stated that spouses or other guests should not attend company-sponsored informational presentations unless these individuals are health care professionals for whom the informational presentation is appropriate. The PhRMA Code clarifies that attendance by friends, significant others, family members and other guests of a speaker or invited attendee is not appropriate, unless these individuals have an independent, bona fide educational need to receive the information presented.
The updated Code will take effect January 1, 2022.