Rosemont voluntary admission: five sales staff lacked ABPI Medical Representatives Exam (AUTH/2648/10/13)

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Key facts

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Case number	AUTH/2648/10/13
Company	Rosemont Pharmaceuticals Ltd
Case type	Voluntary admission (treated as a complaint under Paragraph 5.6 of the Constitution and Procedure)
Issue	Failure of five long-standing sales staff to sit the ABPI Medical Representatives Examination after exemption removed in 2006
How identified	Compliance review during/after takeover by Perrigo
Applicable Code year	2012
Complaint received	28 October 2013
Voluntary admission received	29 October 2013
Case completed	28 November 2013
Appeal	No appeal
Breach clauses	Clause 9.1; Clause 16.3
No breach clauses	Clause 2
Sanctions	Undertaking received; Additional sanctions: Not stated

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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Rosemont Pharmaceuticals voluntarily informed the PMCPA that five long-standing members of its sales team had not taken the ABPI Medical Representatives Examination when an exemption was removed in 2006.
The individuals had passed the ABPI Generic Representatives Examination and had previously been exempt (they were nurses prior to entering the pharmaceutical industry).
The issue was discovered during a compliance review after Rosemont was taken over by Perrigo.
Rosemont proposed that the affected staff would sit the exams within 12 months and pass both papers within 24 months, with termination from sales roles if they failed.
The Panel was concerned the issue was only identified around seven years after the exemption ended and that Rosemont’s proposed timeline did not reflect the Code’s supplementary information about seeking an extension from the Director.

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Breach of Clause 16.3 was ruled.
Breach of Clause 9.1 was ruled.
No breach of Clause 2 was ruled.
The Panel indicated the company should ensure the relevant employees contacted the Director forthwith and should not carry out the medical representative role unless an appropriate extension had been granted.

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