Amgen: Incorrect Disclosure UK entries for a health professional with the same name (AUTH/3140/12/18)

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Key facts

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Case number	AUTH/3140/12/18
Complainant	Health professional
Company	Amgen
Issue	Incorrect Disclosure UK entries showing transfers of value to the complainant
Applicable Code year	2016
Complaint received	21 December 2018
Case completed	10 August 2019
Appeal	No appeal
2015 outcome	No breach of Clauses 7.2, 24.1; consequently no breach of Clause 9.1
2016–2017 outcome	Breach of Clauses 24.1, 7.2, 9.1
Clause 2	No breach
Sanctions	Undertaking received; additional sanctions not stated

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

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A health professional complained that Disclosure UK incorrectly showed they had received financial support (transfers of value) from Amgen.
The complainant said they had never received support or had any contact with Amgen, and alleged reputational damage and potential NHS Fraud investigation risk.
Amgen reviewed the Disclosure UK portal and confirmed the entries shown for 2015, 2016 and 2017 (for Amgen) were incorrect for the complainant.
Amgen asked ABPI (4 Jan 2019) to suppress the incorrect data; due to a portal change, it was not removed from public view until 11 Jan 2019.
Amgen explained there were two health professionals with the same first and last name who had worked in the same area/hospital group and therapy area; the wrong person was matched on the portal.
2015: Panel considered Amgen had submitted the correct person’s details and it was unclear how the portal displayed the complainant instead; complainant did not prove it was due to Amgen’s error.
2016–2017: Panel considered Amgen incorrectly submitted the complainant’s details (identity code selected in error), leading to publication of transfers of value against the wrong individual.

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2015 disclosures: No breach of Clauses 7.2, 24.1 and consequently no breach of Clause 9.1.
2016 and 2017 disclosures: Breach of Clauses 24.1, 7.2 and 9.1.
No breach of Clause 2 (Panel did not consider the circumstances warranted particular censure; error appeared limited to one individual with no evidence of systemic issues).
Clause 24.7: raised by the case preparation manager, but the Panel made no ruling as the complainant had not made an allegation under this clause.
No appeal.

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Clause 7.2 (Breach for 2016–2017; No breach for 2015)
Clause 9.1 (Breach for 2016–2017; No breach for 2015)
Clause 24.1 (Breach for 2016–2017; No breach for 2015)
Clause 2 (No breach)
Clause 24.2 (Referenced by Panel as describing transfers of value covered by 24.1; no separate ruling stated)
Clause 24.7 (Raised; no ruling)

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