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How Transparent Is Transparency?

The second annual publication of transfer of value (TOV) data has just been publically disclosed. For those of you that it passed by, it seems to have generated very little air-time, even within the industry, let alone outside of it. As the dust settles and numbers are crunched, we should now be able to benchmark against the inaugural data, giving it more significance, relevance and validity.
So, what have we learnt? Is the EFPIA mission – to provide a greater understanding of the merits and ethics of the interactions between pharmaceutical companies and healthcare professionals (HCPs) – bearing any fruit?The data published gives us oversight of how financial interactions are apportioned, how much money is spent on R&D related activities versus commercial activities.

The data published gives us oversight of how financial interactions are apportioned, how much money is spent on R&D related activities versus commercial activities, fee for service and honoraria payments. We can analyse this information and draw our own conclusions as to the spend ratios, but I have found it hard to put these numbers into any real context, even for someone like me, involved in the sector every day. The EFPIA vision of enhanced transparency is a noble strategy, however the publication of these astronomical figures does very little to teach the layman about the intricacies of how pharmaceutical companies and the industry operate.

What disclosure hasn’t taught us, or made any effort to promote, is just how much money pharmaceutical companies spend in bringing a product to market; the years of research and development, the clinical trials programmes and the cost of those products that don’t come to market, which are effectively written-off.

Consider Spain as an example. The pharmaceutical industry made €496 million in payments to the medical sector in 2016, according to Farmaindustria. €190m of that spend was in research and development contracts and €207m towards HCPs: €119m was dedicated to HCP participation in scientific activities and professional meetings (registration fees, travel and accommodation expenses) and €88 million to professional services. A further €33m was spent on donations to healthcare organisations.

The €119 million spent on attendance at meetings and events, makes no reference to the educational value to HCPs attending or to the advancement of science. I haven’t been able to find out how or why the €33 million in donations was spent, or whether it was enough. I have also struggled to find any kind of commentary to suggest that the spend ratio is fair or justifiable. Are pharma companies spending a proportionate amount to their product portfolio, their market share, and sales figures or their R&D budget? Surely if it is transparency we seek, we need to appreciate how this spend is representative in all corners of the sector?

There is very little context or insight provided in the publication of these figures to add any real value to the disclosure and to help educate the masses and create a greater sense of transparency. I made comment about this during the maiden publication, suggesting that that the industry (EFPIA, national associations or pharma companies themselves) do very little to promote disclosure, probably for fear of being scrutinised. It seems that this is still the case.

In some markets, the paucity of HCPs who provide their consent to publicise their financial interactions raise the question; how transparent is transparency? It has been reported by the ABPI that in the UK only 70% of HCPs gave consent. More intriguingly, the anonymous 30% equated to 48% of the amounts paid to HCPs. Those receiving the most are not willing to put their hands up and literally, be counted. These numbers aren’t exclusive to the UK. In Ireland, it was 55% and in Germany, a meagre 28% (approximately) providing consent. On the other hand, the pharmaceutical companies are trying to be transparent by disclosing aggregated sums for those HCPs who haven’t provided consent.

I firmly believe that greater transparency is positive for our industry. However, I am of the opinion that more needs to be done if we want genuine transparency and gaps in the data must be plugged. Questions should be asked of HCPs not wanting to publically disclose as to why they are taking this stance. The natural question to ask is what do they have to hide? I’d suggest that would be the public’s perception. In the interests of creating an open book environment, will pharma companies move to distance themselves with HCPs who are not open to transparency. If not, should they? And if they do, who benefits then?

There are still so many questions to ask of TOV disclosure and its validity before we can look and decide on its success. As we reach the end of the school year and as parents we read our child’s end of year report, my assessment of TOV disclosure would be: there remains room for improvement and more to achieve.

How transparent is transparency

20th September 2017

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