Where healthcare organisations receive monies from companies should the disclosure be against individual institutions (hospitals prescribing) or at a Foundation Trust level?

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.

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

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.

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.

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.

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.