Professional Education Support Wyeth Pharmaceuticals Melinda Somasekhar, PhD.

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Presentation transcript:

Professional Education Support Wyeth Pharmaceuticals Melinda Somasekhar, PhD.

The views and opinions that I am going to present are solely my own and do not represent those of Wyeth Disclosure

CME is a process of lifelong learning that serves to maintain, develop, or increase the knowledge, skills, professional performance, and relationships that physicians use in the care of patients. Definition of CME

Who were the Players in CE Activities? Commercial supporter Medical education company Accredited provider Faculty Audience

History of CME History of CME CME was not learner oriented CME was activity oriented How many program one did How much they cost How many people attended them *

Sources Impacting Commercial Support Government and state agencies (i.e. FDA, OIG) ACCME guidelines and CME providers Medical agencies/societies (i.e. AMA, AAFP,AOA, ACPE, and ANCC) Industry Standards (PhRMA)

Primary Regulatory Bodies FDA – Food and Drug Administration –Regulates industry support of CME –Final Guidance on Industry-supported Scientific and Educational Activities 1997 OIG - Office of Inspector General –OIG Compliance Program Guidance for Pharmaceutical Manufacturers 2003 –Anti-kickback statute –False claim act

FDA Final Guidance - 12 Factors for Independence (continued) Identified by FDA in Final Guidance communication in December 1997 As the number of factors violated increases so does the companys risk/liability

FDA Final Guidance - 12 Factors for Independence (continued) Providers failure to meet standards - independent, balanced, objective or scientific rigor Restrictions on multiple programs Influence on audience selection or invitation by company sales or marketing Opportunity for meaningful audience discussion

FDA Final Guidance - 12 Factors for Independence (continued) Product-related information from CE activity is to be disseminated only on unsolicited request or through independent provider No promotional activities by the commercial supporter in CE program meeting room Absence of complaints by provider, presenters, attendees

Provider (not company) controls content, planning, and speaker selection Full disclosures –Company funding of program –Relationships between company, provider, speakers, and moderators –Discussion of unapproved uses of products FDA Final Guidance - 12 Factors for Independence (continued)

Program focus - independent, non- promotional, educational Relationship between company and CE provider does not influence CE activity Involvement between provider and company sales/marketing FDA Final Guidance - 12 Factors for Independence (continued)

OIG Provided Guidance in 2003 CME has now come under scrutiny Commercial support in the form of grants to HCP have elevated anti-kickback concerns Commercial influence over programs, including the selection of presenters/faculty, is not an appropriate marketing practice In essence, following the dollar and determining if it was used to influence a CE activity to promote use of a product

Recent Fines and Penalties Est. Cost (in millions $) TAP875 Abbott622 Warner-Lambert(Pfizer)430 AstraZeneca355 Bayer271 GSK88 Pfizer50 Genentech30

Internal Sources Impacting Commercial Support of CE Government Agencies Public Scrutiny Resources External Other Pharma Industry

Sources Impacting Commercial Support Government and state agencies (i.e. FDA, OIG) ACCME guidelines and CME providers Medical agencies/societies (i.e. AMA, AAFP,AOA, ACPE, and ANCC) Industry Standards (PhRMA) News agencies (WSJ, NY Times, CNN) Lawsuits Clinical data (current and emerging) Treatment Guidelines Company Policies and Guidelines Budgets

What Does Pharma do to Reconcile the Rules Separate grant fulfillment functions from Sales & Marketing Move education to Global Medical affairs Hire educators Creation of Grant Review committees

What Does Pharma do to Reconcile the Rules Developing Compliance programs Developing Policies for Promotion and Independent Education Developing Training to Support Policies

What Does Pharma do to Reconcile the Rules Requiring firewalls when dealing with medical education companies Developing procedures to ensure Independence Seeking advice from meetings focused on the current environment as well as seeking outside counsel

Who are the Players in CE Activities? Accredited provider Medical education company Faculty Audience Commercial supporter

Early Reactions of Marketers to Proposed Changes CME has become too risky Were not doing anything wrong Why should we support CME If we cannot have input we will not support it This does not make sense Why have a committee approach to funding CME Our Medical Affairs Group handles it now We will not change our approach – will wait and see

When is it Appropriate for Industry to Support Independent Medical Education? Educational program would benefit patient care Issues or topics are of interest and of need to the medical community New data or information has become available that benefits patient care

When is it Appropriate for Industry to Support Independent Medical Education? Good business to support the communication or valuable information to healthcare providers Policies and guidelines governing independent education can be adhered to and followed

When is it NOT Appropriate for Industry to Support Independent Medical Education? A medical education need does not exist Program or educational activity is focused on only a single product

When is it NOT Appropriate for Industry to Support Independent Medical Education? Education that serves only commercial interests without improving patient care Policies and guidelines governing independent education cannot be met

How Can We Design the Most Effective Independent Education and Stay Compliant? Appreciation for laws, guidelines, policies and how they drive each stakeholders behavior Learn how to engage and work together to better serve HCP needs and improve patient care Understand all stakeholders roles

Marketer Realization: We Cannot Stop Supporting CME CME is a powerful tool to improve the patient outcome CME is a powerful tool to improve the patient outcome

Need to Institute Basic Principles of Adult Education Physicians self-assessment of their competencies Understanding how physicians learn Understand why physicians learn The environment physicians practice in Practice-based issues The improved patient outcome

Most Crucial Elements of Education Designing activities for physicians that would allow them to learn from their clinical experience Improving patient outcome

Need to Institute Basic Principles of Adult Education Gap in the education Needs assessment Learning objectives Designing the activity to meet the learning objectives The cost of doing the program

Commercial Focus – Moving Forward Compliant within policies and guidelines Strategic with business objectives Fiscally accountable and responsible

New World of Clinically Based CME Strong Relationship Between all parts of Educational Community CME provider Physicians Educators

Summary Designing CME programs that include educational strategies how physicians learn, influence physicians knowledge, and improve health care outcome is more critical than ever.