PhRMA Updates Healthcare Professional Interaction Code

Pharmaceutical Research and Manufacturers of America (PhRMA) updated 8/6 its Code on Interactions with Healthcare Professionals, to take effect 1/1/22. Attorneys McKenzie Cato and Alan Kirschenbaum (Hyman, Phelps & McNamara) write in their FDA Law Blog that the latest changes are primarily focused on speaker programs, including meals and drinks offered, the venue used, and attendance at such programs.

“These revisions appear to be responsive to an 11/16/20 Special Fraud Alert issued by the HHS Office of Inspector General (OIG),” the attorneys say. “While PhRMA does not reference the OIG Special Fraud Alert in its announcement of the revised code or its summary of revisions to the code, the substantive updates to the code are directly traceable to OIG’s critiques of speaker programs.”

The attorneys say that while the PhRMA code is a voluntary industry code, its important function in risk reduction cannot be overstated.