AUTH/2865/8/16: Anonymous (non-contactable) v Sanofi — MEGS nurse advisor service via consultancy company (No breach) | PMCPA Case

📊

Key facts

⌄

Case number	AUTH/2865/8/16
Parties	Anonymous, non-contactable complainant v Sanofi
Complaint received	03 August 2016
Case completed	19 December 2016
Published	February 2017 Code of Practice Review
Applicable Code year	2016
Therapy area / product	Not stated (described as a specific condition/therapy area; products not named)
Activity at issue	Alleged industry-funded audits/workshops and inducement; Sanofi’s involvement limited to a MEGS patient management and nurse advisor service delivered via a consultancy company (early 2014–28 Feb 2015)
Panel decision	No breach of Clauses 2, 9.1, 18.1, 19.1, 19.2, 21, 23.1
Sanctions	None
Notable observation	Panel queried whether 14 representative visits in 2014 complied with Clause 15.4 guidance (call frequency), and requested the company be advised

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

An anonymous, non-contactable complainant alleged a therapy-area training/consultancy company (run by a health professional with NHS roles and alleged prescribing influence) was conducting industry-funded audits and workshops that drove irregular use of sponsors’ products.
Allegations included patients being initiated/switched to a sponsor’s medicine with little consideration of alternatives, and that industry funding for accredited workshops could be seen as an attempt to “buy the business”.
The complainant also alleged coercive behaviour: that companies were told their products would not be used in a CCG unless they funded the consultancy company’s activity.
Sanofi stated it had only worked with the consultancy company on a patient management and nurse advisor service delivered as a medical and educational goods and service (MEGS), running from early 2014 to 28 February 2015, and had not funded audits or the alleged workshops.
The MEGS service involved specialist nurses assessing patients and reviewing treatment in line with locally agreed guidance; practices retained clinical responsibility for prescribing decisions.
Sanofi provided documentation (service operating procedure, contracts) and sales trend data, stating there was no evidence the service drove disproportionate uptake of Sanofi products.
The Panel noted it could not seek further detail from the complainant and that no supporting evidence had been provided.

⚖️

⌄

No breach of the Code was found.
The Panel ruled the complainant had not established, on the balance of probabilities, that Sanofi’s MEGS service was an inducement to prescribe or otherwise contrary to the Code.
The Panel found no evidence that Sanofi had engaged in the alleged clinical audits or training workshops referenced in the complaint.
The Panel stated there was no evidence Sanofi had employed the named health professional as a consultant.
Panel additionally queried (outside the pleaded clauses) whether 14 representative visits to the named health professional in 2014 complied with Clause 15.4 (frequency of calls), and asked that the company be advised of its views.

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access