Working with pharmaceutical companies is a necessary and often beneficial aspect of a pharmacist’s role, particularly when working in a commissioning, clinical, prescribing or procurement role. In light of recent press interest and upcoming changes to legislation the GHP wish to issue the following guidance to its members: If you are invited to attend an advisory board being run by a pharmaceutical company or be involved in other similar paid work or sponsorship:
- Check your employer’s policies on the matter. Most employers will have some information in their Medicines Management and Human Resources policies
- Ensure you are familiar with or have read national guidance and that you are compliant with these documents i.e. Standards of business conduct for NHS staff (HSG(93)5) and Best practice guidance for joint working between the NHS and the pharmaceutical industry (DH 2008) (although local guidance should take account of these).
- Complete the relevant declarations to your employer. Ensure you include detail on travel and subsistence, as well as fees/honoraria received
- Consider other committees or bodies you sit on within our out with your direct employer e.g. regional formulary or area prescribing committees and complete any relevant declarations to those bodies
- Ensure any promises you make to take back to your ‘day job’ are ethically sound – is it something you would have been happy to do had you not sat on the advisory board?
- Consider associated hospitality – having an event for UK staff hosted at a city centre hotel near a railway station or airport is probably justifiable for convenience. Having it in Dubai probably isn’t. That said, some advisory boards involve wider geographical areas so for example economy class flights to a central European city may be reasonable.
- Think about how the payment and hospitality could be perceived by the public; could it be said to be proportionate and reasonable?
- Do not make inflated claims about your position, influence or sphere of responsibility
- If you are being paid for the work, ensure it is done in your own time
- Advisory boards must be advisory and not promotional. A company using an advisory board as promotional is breaking the ABPI Code of Practice and you must report it to the Prescription Medicines Code of Practice Authority (PMCPA)
- Any income you receive will be taxable, so inform Her Majesty’s Revenue and Customs
- Be mindful if you’re asked to bring any information from your employer (e.g. usage of certain drugs, current formulary choices) to ‘help with discussions’. Consider what information is publically available and what is commercial in confidence. If you are in any doubt, discuss with your employer, or simply say no.
- Be aware of any confidentiality arrangements you have signed up to at the meeting itself
- If a meeting is set up by a third party, ensure you know which company they are working on behalf of It is worth noting this is issued as guidance alone, and that individuals are still responsible for their action.
Should you require any further information or advice on this, or any other related matter, please contact your local GHP representative. If you are not yet a member, please join above.