What should pharmaceutical companies include in the 'Total' column on the Disclosure template?

  • (24.1) Lawful Disclosure

    Companies must ensure that they have appropriate arrangements in place to lawfully disclose information about transfers of value and that recipients are aware of the process for disclosure.

  • (24.1) Transfers of Value

    Disclosure is required even if the payments etc are made by overseas affiliates, head offices in the UK or overseas and UK-based offices.

  • Clause 28.1 (24.1) Mode of Disclosure for Health Professionals, Other Relevant Decision Makers and Healthcare Organisations

    There is a central platform for disclosure in the UK which companies must use. The template to be used is available from the PMCPA website www.pmcpa.org.uk.

  • Clause 28.2 (24.2) Further Information

    The clauses of the Code noted in Clause 28.2 should be consulted for further information about the requirements. In addition, the requirements of Clauses 10.1 and 10.10 should be borne in mind in relation to meetings.

  • Clause 28.2 (24.2) Disclosure of Contributions to Costs Related to Events/Meetings

    If when providing sponsorship to a healthcare organisation, institution, other organisation etc in relation to their own event, a company contributes towards the overall cost of subsistence (food and drink), then this must be included in the disclosure of the cost of the sponsorship to the healthcare organisation, institution, other organisation etc. Where a company supports individual health professionals or other relevant decision makers (directly or indirectly) to attend events/meetings, there is no requirement to disclose subsistence (food and drink) as in Clause 10.1.

  • Clause 28.5 (24.9) Disclosure of Transfers of Value to Individual Health Professionals and Other Relevant Decision Makers

    If an individual health professional or other relevant decision maker receives a number of transfers of value from a company and decides not to agree to disclosure of one or more of those transfers of value, then that company can disclose all of that individual’s transfers of value in its aggregate amount.

  • (24.1) Lawful Disclosure

    Companies must ensure that they have appropriate arrangements in place to lawfully disclose information about transfers of value and that recipients are aware of the process for disclosure.

  • (24.1) Transfers of Value

    Disclosure is required even if the payments etc are made by overseas affiliates, head offices in the UK or overseas and UK-based offices.

  • Clause 29.1 (27.7) Further Information

    An indication of the patient organisation’s total income and/or the company’s support as a percentage of the patient organisation’s total income may be given. Companies are encouraged to be prepared to make available up-to-date information about such activities at any time in response to enquiries.

    A template to disclose the information required in relation to patient organisations is available from the Prescription Medicines Code of Practice Authority (PMCPA) website www.pmcpa.org.uk. The use of this template is optional.

  • Clause 30 (New) Disclosure of Contracted Services Provided by the Public, Including Patients and Journalists

    The arrangements for such services should meet the requirements of Clause 24.

    Disclosure must be in the first six months in the calendar year following that in which the payments were made. The information which must be disclosed is the total amount paid in a calendar year to the public, including individual patients, journalists and members of the public who have provided services. The total number of individuals must be given. The names of the individuals need not be disclosed. Companies may, of course, give greater detail, for example, by giving separate figures for different categories of service or by providing details of the maximum and minimum payments etc.

    A template to disclose the information required in relation to the public etc is available from the PMCPA website www.pmcpa.org.uk. The use of this template is optional.

    All reasonable steps should be taken by companies to similarly disclose their best estimates of fees paid to UK individuals by overseas affiliates, head offices in the UK or overseas and UK-based European offices.

  • (24.1) Lawful Disclosure

    Companies must ensure that they have appropriate arrangements in place to lawfully disclose information about transfers of value and that recipients are aware of the process for disclosure.

  • (24.1) Transfers of Value

    Disclosure is required even if the payments etc are made by overseas affiliates, head offices in the UK or overseas and UK-based offices.

  • Clause 31.1 (New) Date of Implementation for Disclosure of Contracted Services Provided by the Public, Including Patients and Journalists

    The information required by Clause 30 must be publicly disclosed annually in respect of transfers of value made in 2022 and each calendar year thereafter.

This is made clear in the template for disclosure.