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PMCPA Case

GSK at ERS 2022: COPD network meta-analysis slides ruled misleading; MSL presence on promo stand not proven promotional

📅 2021 | 🖉 Dr Anzal Qurbain
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Key facts

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CaseAUTH/3708/11/22
CompanyGSK UK Ltd
EventEuropean Respiratory Society (ERS) meeting, Barcelona (September 2022)
Complaint received16 November 2022
Case completed15 December 2023
Applicable Code year2021
AppealNo appeal
Main issues(1) MSL presence/behaviour on promotional stand; (2) Symposium slides on COPD triple therapy NMA (Ismaila et al) and comparator messaging
Breach clausesClause 5.1; Clause 6.1; Clause 6.2
No breach clauses (as listed)Clause 2; Clause 5.1; Clause 9.4; Clause 15.6
SanctionsUndertaking received; Additional sanctions: Not stated

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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, contactable complainant raised concerns about GSK UK Ltd’s activities at the European Respiratory Society (ERS) congress in Barcelona (September 2022).
  • Two issues were alleged: (1) UK medical science liaison (MSL) staff being present on a promotional (commercial) stand and allegedly soliciting product questions without having passed the ABPI representatives’ exam; (2) allegedly misleading comparator claims in two GSK-sponsored symposium presentations about a network meta-analysis (NMA) of COPD triple therapies.
  • The symposium was titled “How molecular pharmacology is improving patient outcomes in COPD”. The complaint focused on the presentation “Are all triple therapies the same? Learning from head-to-head and indirect comparisons” (NMA by Ismaila et al).
  • GSK stated it had two booths (commercial and a separate non-branded medical booth), provided briefings/training, and said it found no evidence that MSLs solicited questions on the commercial stand.
  • GSK said the “Real-world evidence on triple therapy: what have we learned?” talk did not include NMA slides or mention Trimbow or Trixeo; the Panel agreed it was not the subject matter of the complaint.
  • The Panel’s key concern on the NMA slides was that, overall and on balance, the slide design and wording created an impression of superiority and did not give sufficient weight to NMA limitations; important qualifications were effectively relegated to footnotes and were not consistently carried through to summary/conclusion slides.
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Outcome

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  • Breach of Clause 5.1 (Failing to maintain high standards) in relation to the symposium presentation slides.
  • Breach of Clause 6.1 (Making a misleading claim) in relation to the symposium presentation slides.
  • Breach of Clause 6.2 (Making an unsubstantiated claim) in relation to the symposium presentation slides.
  • No breach of Clause 9.4 (ABPI exam for representatives) regarding MSL presence/activities on the commercial stand (complainant did not establish MSLs acted in a promotional capacity).
  • No breach of Clause 15.6 (disguised promotion) regarding MSL presence/activities on the commercial stand.
  • No breach of Clause 2 (x2) (discredit to the industry) and No breach of Clause 5.1 for the MSL/stand allegations.
  • No rulings were made about an alleged Trixeo vs Trimbow comparison because the Panel could not identify any direct comparison between them.
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