In vino veritas…. but should you be serving it at a bureau program?

5 March, 2023 /
Compliance Procedures

Over the past several months L&M Healthcare’s client teams have been actively participating in planning and discussions with our clients in preparation for their 2022 Peer-to-Peer campaigns. Everything from program types, speaker counts, allocations, regional distribution, and of course BUDGETS. What must be taken into consideration during these discussions is of course the new PhRMA guidance on bureau events (insert link) which provided direction on two important components to a bureau campaign; 1) Appropriate venue selection and 2) Alcohol consumption at local live events. Let’s tackle each…

Venues

The latest PhRMA code reiterates its long-standing position that ‘meals offered as an incidental business courtesy to attendees of company-sponsored speaker programs should be modest as judged by local standards” and that “high-end restaurants and other such venues are not appropriate locations for speaker programs.” Now more than ever, careful attention must be paid to the proper selection of venues for meal-based events so as not to appear to be overspending on event participants. As a result of this renewed guidance many of L&M Healthcare’s clients are suppressing the meal maximum per person even lower than before. Some as low as $90/person all in for dinner. This conservative approach to meal spend further emphasizes the need for a Speakers Bureau partner which understands the rules, has a technological solution to seamlessly support business rules and event planning, and a customer service team which will support the field force and work tirelessly to find great venues and negotiate pharma specific contracts. We have over 10,000 venues vetted in our STARS system and will never let your salesforce down.

Booze!

The latest PhRMA code further states that “pharmaceutical companies should not pay for or provide alcohol in connection with speaker programs.” That sound you heard was the vintners and scotch purveyors of the world uttering a collective gasp and sigh. The days of $150 cabernet and $20 pours of Ardbeg 10 are alas over. Many of us enjoy a boozy beverage with our meal, particularly when we are with friends and colleagues. Afterall “In Vino Veritas”, the great social lubricant allows for free conversations and open dialogue. But let’s look at the upside. First and foremost safety, unfortunately evenings of consumption can lead to physical and legal harm later on which your company no longer shares in culpability for. Additionally, those food budgets we talked about above, well they got a lot easier to meet or beat without the addition of expensive spirits. Finally, we can now focus solely on the content and value which your programs bring to HCPs for the benefit of their patients, without the cloud of impropriety. Over the years and decades of bureau events the easiest road to potential fraud is that part of the event receipt which lists the wine and cocktails. That said some clients are allowing HCPs to purchase their own drink at the bar prior to entering the event space, but strictly forbid reordering from the venue service staff when the program has begun. Somewhere in the interpretation of this new ruling is where your company will fall, and L&M will be here to ensure business rules are created and enforced.

So, save the fancy restaurant and expensive wine and cocktails for dinners with friends and family. As we enter the holidays we want to extend our wishes to you yours for a happy and healthy holiday season!

Thanks for reading.

Adam Margolis, CEO, Managing Partner

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