PhRMA Responds: Code on Interactions with HCPs Updated Following Fraud Alert on Speaker Programs

PhRMA Adopts OIG's Position that Companies Should Not Pay for or Provide Alcohol in Connection with Speaker Programs On August 6, Pharmaceutical Research and Manufacturers of America (PhRMA) released an updated and enhanced version of its voluntary Code on Interactions with Health Care Professionals (HCPs). The update to the Code is at least partly in response to the Special Fraud Alert issued by the Department of Health and Human Services Office of Inspector General (OIG) in November 2020 related to company-sponsored speaker programs and addresses several of the risk areas OIG identified in the fraud alert. The updated Code elaborates that incidental meals provided by company representatives in connection with an informational presentation to a health care professional must be "modest as judged by local standards" and should be provided only "where there is a reasonable expectation, and reasonable steps are taken to confirm, that each attendee has a substantive interaction or discussion with the company representative."