Sometimes when classifying external speaker presentations which form part of a promotional meeting, it can be a challenge to confirm the intent or classification of the material in relation to the content of the presentation.
When using an external consultant to provide speaker services, companies may instinctively classify their presentation as a promotional piece, even when they are unsure what the exact content of the speaker’s slides will be. However, by classifying the slide deck as “promotional”, it must adhere to the requirements of the advertising legislation and the IPHA/MfI Code, and consequently it must contain abbreviated prescribing information (aPI) for the related company medicinal product(s).
It must be considered how inclusion of product aPI will be perceived by the audience if it subsequently arises that there is no, or limited, mention of that product in the slides. Will this change the audience’s perception of the meeting objectives, or possibly lead them to feel that the opinions of the HCP on the topics being discussed are endorsed by the company, even if they were intended to be purely for the attendee’s own clinical education or development?
It is always advisable to provide a thorough speaker briefing with consultants when they are contracted to speak at a meeting. This will provide more clarity to the speaker on what is expected of them. Consultants providing a service on behalf of a company must be made aware of relevant legislative and Code requirements that they must adhere to when speaking on behalf of the company. It can also be beneficial for the company as the speaker should be able to guide the company on their intended content for the presentation so that the company can determine how the presentation should be classified.
It is important to note that although some elements of a promotional meeting may include non-promotional content, all of the content for a non-promotional meeting must be defined and considered to be non-promotional.
The following chart may be used as a guide when considering how to classify content for a promotional meeting:
Lucy Tobin, Healthcare Compliance Consultant