As the pharma industry looks to virtual meetings and teams work remotely, what considerations are there around the ABPI Code and virtual promotional meetings?
Whilst the NHS has undoubtedly got bigger things to worry about than wonder how pharma will promote its medicines without face-to-face calls and meetings, pharma has a lot to be worried about in these unprecedented times: from cancelled activities and unused materials to field customer-facing teams confined to working at home.
It’s true to say that many of us are adapting to new ways of working and things may return to a ‘new normal’ after lockdown. But as we are working remotely there is, undoubtedly, a rise in the use of virtual meetings. This article does not address how we should increase digital promotion during lockdown but suggests ways we can embrace it in the future and remain compliant with the ABPI Code of Practice (Code). This will be the first of a series of articles on digital promotion, this one exploring virtual promotional meetings.
“It is always useful for guidance to consider case rulings as well as what might go wrong with an activity, in order to then find ways to mitigate these risks”
Code and Guidance
Digital marketing within the pharmaceutical industry has been utilised for many years. The topic causes much debate with agencies and pharma generally asking the ABPI for ‘more clarity in the Code on specific digital areas’ and the PMCPA responding in several ways, including the following:
- The PMCPA produced guidance on digital communications in 2014 (updated since).
- ‘Clause 28: The Internet’ was renamed to ‘The Internet and other digital platforms’ in 2019.
Despite this, there continues to be complaints relating to digital communications, with 27 related PMCPA case rulings published in 2019, suggesting companies’ own guidance is required.
Therefore, in order to better understand how we can promote our medicines digitally, it is this company guidance that should be clear, unambiguous and based on common practice.
It is always useful for such guidance to consider published PMCPA case rulings. This helps us to understand what might go wrong with an activity, in order to then find ways to mitigate these risks. These mitigation ideas essentially form the basis of a ‘compliance checklist’ for this activity, which is then ideal to sit in company guidance.
If Code requirements don’t help us, is a better understanding of them able to at least not hinder us in optimising future digital opportunities?
Digital Promotion Example: Virtual Meetings Compliance Checklist
Over and above the normal requirements for face-to-face promotional meetings, the table opposite describes the extra Code compliance considerations if such a meeting was held virtually.
PMCPA case rulings, Standard Operating Procedures and Signatories
As with all compliance checklists, insight is gleaned from relevant PMCPA case rulings to develop meaningful and comprehensive checks. In their absence, company standard operating procedures should be clear and unambiguous. In addition, discussing planned activities with modern and constructive final signatories plays an important part in achieving not just compliant virtual meetings, but ones that are also highly educational, useful for customers and commercially impactful.
|Delegate may not have been invited and therefore not appropriate.|
|Delegate has not given permission to receive promotion via digital methods.|
|Email invite may disguise the fact that the meeting is promotional.|
|Member of the public might access meeting and be inadvertently promoted a medicine.|
|Member of the public might overhear/see meeting.|
|Prescribing information embedded in content is not visible or missing|
|Link to prescribing information missing/not working.|
|Delegates choose to dial-in (rather than log-in) and therefore will not see obligatory aspects of the meeting content.|
|Certification is improper.|
|Third parties may let the pharma company down.|
Dr Rina Newton is Managing Director of CompliMed. Go to www.complimed.co.uk