PhRMA code change presents an opportunity to drive value in next-level HCP engagement

Like that tiny object approaching in a car’s rearview mirror, indistinct until the gap of distance closes, we saw it coming: more restrictions on how pharma companies can engage with healthcare professionals (HCPs). This time, the focus is on the use of alcohol and high-end restaurants for company-sponsored speaker programs intended for meaningful education, not entertainment.

Could restrictions or elimination of meals from HCP interactions be next for some companies or for the entire industry? Maybe. But the pharma sector should be confronting a more important question. Is it possible that eliminating items of value associated with HCP interactions could prompt pharma companies and HCPs to focus on the value of the engagement, not the food and beverages associated with them?

This discussion took center stage with the news that on August 6, 2021, the Pharmaceutical Research and Manufacturers of America (PhRMA) unveiled updates to the PhRMA Code on Interactions with Health Care Professionals (PhRMA Code). Among other changes, the PhRMA Code unveiled restrictions related to company-sponsored speaker programs, including eliminating alcoholic beverages and the use of high-end restaurants. These restrictions are accompanied by additional emphasis on the purpose of speaker programs, which should be “to present substantive educational information designed to help address a bona fide educational need among attendees.” These events provide opportunities for many HCPs to stay educated on disease state areas and therapies. At ZS, we closely monitor even the softest tremors to anticipate which of these could potentially shake up pharma’s long-standing practices and business models. As importantly, we aim to stay three steps ahead by analyzing emerging trends to lead the conversation about how change creates opportunity.

A harbinger of PhRMA’s revised Code for HCP interactions arrived in November 2020 when the Office of Inspector General (OIG) of the Department of Health & Human Services issued a Special Fraud Alert involving speaker programs. The OIG reinforced that when a drug or device company engages in “entertainment, recreation, travel, meals or other benefits in association with information or marketing presentations,” such arrangements may potentially implicate the federal Anti-Kickback Statute. In the last three years, drug and device companies have reported paying nearly $2 billion to HCPs for speaker-related services.

With stakes this high, it’s not surprising the government, industry associations and the public are watching. Because the mission of life sciences companies is to better the lives of the patients they serve, it’s only right that patients should expect that treatment decisions are made in their best interest and based on independent clinical judgment—not on whether someone buys HCPs a drink.

If PhRMA has considered alcoholic beverages and high-end restaurants to be inappropriate exchanges of value at company-sponsored speaker programs, then more focus on meals may be in the crosshairs next. ZS AccessMonitor data estimates 20%–30% of pre-pandemic office calls were meals-based meetings (ZS AccessMonitor Report, March 2021).

If elimination of meals with HCPs happens, this could have unique implications for commercial sales representatives and force the question: Are these interactions with HCP driving enough value? We see a window of opportunity if pharma uses these changes as a catalyst to transform the relevance and importance of the information they're exchanging in these HCP meetings. After all, HCPs are asking for it.

The core of the manufacturer and HCP relationship is the exchange of important information to help support clinical decision-making. Medical knowledge is estimated to double every 73 days, and in categories like oncology, the velocity of new information and new products is even faster. It’s a firehose. Given this, HCPs are increasingly relying on pharma companies to help them sort through disease states and available treatment options. They’re looking for help with how to determine which patient types stand to benefit most based on a specific understanding of data on available therapies.

Yet ZS’s industry knowledge, our work with clients and our ongoing qualitative and quantitative research all point to one truth—HCP interactions with the commercial field force no longer deliver as much value as once believed. Exceptions exist, such as launches and new indication data. But the insights coming out of the pandemic era tell us that HCPs are looking for new content and real educational value. 

Though people are eager to reconnect face-to-face again, the long tail of COVID-19 has changed priorities. Zoom fatigue and telehealth patient appointments have doctors asking, “Do I really need to take another meeting?” And the reality is, they don't.

It’s easy to think it will be fine when we’re back to “normal.” But even pre-COVID-19, the highest-performing specialty reps in the industry secured office meetings with top-tier HCPs only 12–16 times a year (ZS AccessMonitor report, semester 1 2020). ZS estimates post-COVID-19, there will be 20%–30% fewer in-person interactions than pre-COVID-19. What we’re hearing from customers across 13 primary and specialty categories suggests high averages of 10%–20% virtual visits post-pandemic (ZS COVID-19 study, February 2021). This is on average; of course, some systems always will be more restrictive. Meals or no meals, each and every interaction with HCPs is more precious than it’s ever been before.

Changes in what HCPs expect from pharma interactions challenge the entire organization to be more agile—from marketing, sales, medical and key account manager roles, to the data scientists tasked with generating local insights based on real-world data.

When manufacturers deliver on the promise of content-rich interactions, they will engage more effectively and address patient challenges. They will develop new competencies and skill sets to nurture a longitudinal dialogue that leaves customers saying, “My meeting with my rep is always a valuable use of my time.” This will lift the experience for HCPs and build stronger, more trusting and indispensable relationships. Interactions will become richer because knowledge is built over time, making HCPs more receptive to that second and third visit.

While in-office meals and restaurant dining offer opportunities to engage on a personal level and interact with multiple doctors, nurses and other medical professionals, it’s the value of the information that should be at the core of these interactions. And the clinical and education priorities of HCPs and their patients should supersede everything else. 

Of course, pharma sales representatives cannot do it alone. Content-rich engagements mean medical and clinical need to continue to focus on earlier and stronger integrated evidence planning, faster analytics and rapid publication of useful information. Marketing must move away from a scripted story and, instead, design content to support a series of interactions that build information, knowledge and experience over time. Medical Affairs should guide their strategy and execution based on identifying and addressing unmet medical needs through analysis of real-world data. Regulatory Affairs and promotional review processes need to adopt a more streamlined and risk-based approach to the development and review of modular content, which can be configured to more effectively address HCP educational needs. Sales and sales training need to focus on different capabilities and practices—and perhaps some different types of talent. 

HCPs have an appetite for greater value—new content delivered faster than before—in exchange for their precious time. We don’t need dinners and beverages to feed that. We have the know-how and muscles to transform engagement. We just need to flex them.