AUTH/2864/8/16: Anonymous (non-contactable) v Boehringer Ingelheim – consultant/training company engagement (No breach) | PMCPA Case

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Key facts

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Case number	AUTH/2864/8/16
Parties	Anonymous, non-contactable complainant v Boehringer Ingelheim
Issue	Engagement of a consultant and his/her training and consultancy company; alleged inducement/conflict of interest linked to audits and training workshops
Complaint received	03 August 2016
Case completed	19 December 2016
Published	February 2017 Code of Practice Review
Applicable Code year	2014 (with consideration of 2016 Code clauses for later activities as relevant)
Panel outcome	No breach of the Code
Clauses considered	2, 9.1, 18.1, 18.6, 19.1, 19.2, 20.1 and 21
Appeal	No appeal
Sanctions	None

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

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What happened

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An anonymous, non-contactable complainant alleged a therapy-area training and consultancy company (owned by a health professional who was also a specialist nurse) delivered NHS services (audits, mentoring, education, workshops) funded by multiple pharma companies including Boehringer Ingelheim.
The complainant alleged industry-funded “clinical audits” in GP surgeries were associated with irregularly high use of a sponsor’s product and that patients were initiated/switched with little consideration of alternatives.
The complainant alleged accredited workshops (RCGP/RCN) delivered with a named CCG were fully industry-funded, with “staggering” support that could be perceived as “buying the business”.
The complainant alleged coercive behaviour: that pharma companies were told if they did not fund events their products would not be used in the CCG where the health professional had prescribing responsibility/influence.
Boehringer Ingelheim described its interactions: a 2014 evening meeting where it paid the health professional’s speaker fee; two 2-day courses in April and July 2016 where it paid for exhibition stands under contracts with the consultancy company (at the CCG’s request); and funding (paid to a university) for PRIMIS audit-tool training requested by a community healthcare organisation (CHO).
After notification of the complaint, Boehringer Ingelheim put ongoing/future activity involving the consultancy company on hold and issued a certified field force briefing.
The Panel noted Boehringer Ingelheim should have been well aware of the health professional’s dual role (NHS/CCG role and owner of the consultancy company) based on materials provided.
The Panel also noted process vulnerabilities: a fair market value assessment form for the 2014 speaker agreement had not been completed; and the company did not routinely request receipts for conference attendance (outside scope for rulings).

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Outcome

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No breach of the Code was ruled.
The Panel found the complainant provided no evidence to support the allegations and did not establish, on the balance of probabilities, that sponsorship/engagement was an inducement to prescribe or otherwise inappropriate.
No breach was ruled for the cited clauses, including no breach of Clause 2.
The Panel stated the 2016 conference sponsorship was outside the scope of the complaint and made no rulings on it.

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AUTH/2864/8/16: Anonymous (non-contactable) v Boehringer Ingelheim – consultant/training company engagement (No breach)

Key facts

What happened

Outcome

Clauses

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