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PMCPA Case

AUTH/3261/10/19: Complainant v Novo Nordisk (regional medical advisors) – No breach

📅 2019 | 🖉 Dr Anzal Qurbain
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Key facts

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Case numberAUTH/3261/10/19
PartiesComplainant v Novo Nordisk
IssueAlleged conduct of regional medical advisors; concerns about proactive meetings, blurred medical/promotional activity, and alleged call-rate/meeting targets
Complaint received12 October 2019
Case completed3 April 2020
Applicable Code year2019
Clauses considered2; 9.1; 12.1; 15.2
OutcomeNo breach
AppealNo appeal
Additional sanctionsNone stated
Notable Panel commentPanel concerned about Novo Nordisk’s view that RMAs were not representatives and whether promotional vs non-promotional aspects were sufficiently differentiated to ensure compliance

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

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What happened

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  • A contactable individual complained about the conduct of Novo Nordisk regional medical advisors (RMAs).
  • Allegations included that RMAs were meant to be reactive to clinicians but were proactively asking sales representatives to take them into meetings even when not invited.
  • The complainant alleged RMAs pressured representatives to book meetings (including emailing available dates) and attended most meetings with them.
  • The complainant alleged RMAs were “doing more of the selling”, blurring the line between reactive medical activity and proactive promotion.
  • The complainant alleged RMAs had call-rate/meeting targets set by senior managers, creating pressure to see a certain number of customers per day.
  • Novo Nordisk denied call-rate targets and stated RMAs were field-based medical staff with a primarily non-promotional remit, trained and briefed on expected behaviours, and not remunerated based on sales.
  • Novo Nordisk stated joint visits with representatives were not routine and required a legitimate need (eg, HCP request for introduction or to answer technical on-label questions).
  • Novo Nordisk stated RMAs sometimes acted as expert speakers at group meetings (often arranged by representatives) using pre-certified, on-licence slides; it was made clear the presenter was an RMA.
  • The Panel noted the Code’s broad definition of “promotion” and “representative”, and considered that part of the RMA role appeared promotional (eg, proactive on-licence presentations), though this is not prohibited if compliant and clearly separated from non-promotional medical activity.
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Outcome

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  • No breach of the Code was ruled.
  • The Panel found the complainant made detailed allegations but provided little evidence; the burden of proof was not met on the balance of probabilities.
  • No breach of Clause 12.1: the complainant did not establish that meetings constituted disguised promotion.
  • No breach of Clause 15.2: the complainant did not establish RMAs pressured representatives or acted unethically as alleged.
  • No breach of Clause 9.1: insufficient evidence that suggested minimum activity levels (as described) failed to maintain high standards.
  • No breach of Clause 2: the circumstances did not warrant the particular censure reserved for Clause 2.
  • However, the Panel expressed concern about Novo Nordisk’s view that RMAs were not “representatives” and queried whether the role’s promotional vs non-promotional aspects were sufficiently differentiated to ensure compliance; Novo Nordisk was to be advised of these concerns.
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