PhRMA’s New Code: Secret Documents Revealed

The Carlat Psychiatry Blog has concocted, invented, and otherwise created the following satirical secret Q & A document regarding PhRMA’s new Code on Interactions with Healthcare Professionals. This fictitious document is rumored to be circulating in redacted and top secret email accounts among pharmaceutical executives. Read it and weep.


New PhRMA Code Questions and Answers
(Highly confidential. Do not release to press. Destroy after reading.)

Q: Are there any significant changes in the new code that are going to impinge upon my ability to market my product?

A: Absolutely not. As all of our marketing executives know, the most effective marketing tactics, in terms of ROI (return on investment), are: CME (continuing medical education), promotional speaker’s programs, lunches provided to targeted physicians and staff, and big ticket “educational” gifts, such as $100 textbooks and subscriptions to journals. There is nothing in the new code that will in anyway restrict any of these activities.

Q: Why did you decide to ban tchochkes?

A: Primarily based on feedback from drug reps in the field. They were taking up valuable trunk space in their cars, limiting our ability to provide free samples and cherry-picked articles. Physicians were increasingly refusing to accept them anyway. Our internal statistical analysts determined that the yield in new prescriptions directly attributable to these gifts (ROT, Return on Tchotchkes) was less than zero.

Q: What should we do with the thousands of worthless clocks, mugs, and pens that are taking up warehouse space?

A: We are arranging for shipment to Asia, where we understand these are in high demand and may be helpful in our members' overseas marketing campaigns.

Q: You’re killing us with the ban on restaurant meals. That is one of our key marketing techniques.

A: What are you, gullible? Of course we didn’t ban restaurant meals! Look at Section 7, Page 10: “Speaker programs may include modest meals offered to attendees and should occur in a venue and manner conducive to informational communication.”

We understand your confusion, because on page 4 of the new code, we do say: “Any such meals offered in connection with informational presentations made by field sales representatives or their immediate managers should also be limited to in-office or in-hospital settings.” But this applies only to presentations provided by drug reps, not by hired gun physicians. The public doesn’t realize that physicians never wanted to go out to a restaurant with drug reps anyway, because it was a complete waste of their time.

We offer our sincere kudos to the public relations team that crafted this ploy. It has worked so well that many newspapers, including the Los Angeles Times, have communicated this misinformation in their headlines.

Q: Some of our key opinion leaders in orthopedics are concerned that this new code might limit the multi-million dollar payments they have received. Tell me this isn't true.

A: Not to worry, on two counts. First, we have put no limits on cash payments to physician consultants, who are crucial players in our marketing efforts. Second, nothing in the new code applies to either medical device makers or biotechnology companies. So orthopedists can still be paid top dollar to promote your artificial hips and knees.

Q: In a recent Business Week article, PhRMA’s Senior VP Ken Johnson said that “U.S. physicians are committed to quality health care. It’s part of the oath they take. So, despite what critics say, it’s insulting to suggest that doctors would prescribe treatments based on who gave them a slice of pizza, a pen, or a medical dictionary.” Now PhRMA is banning pens. Isn’t this likely to be perceived as an admission that we knew gifts were, in fact, bribes all along?

A: We’ve had many meetings about this thorny issue of “backdated confession.” This was why, in consultation with our top five Madison Avenue advertising firms, we came up with the following wording on page 11 of the code:

"Providing items for healthcare professionals’ use that do not advance disease or treatment education — even if they are practice-related items of minimal value (such as pens, note pads, mugs and similar “reminder” items with company or product logos) — may foster misperceptions that company interactions with healthcare professionals are not based on informing them about medical and scientific issues."

As you can see, this allows us to discontinue outright bribery without admitting that it was ever bribery. Instead, it has been re-labeled as a "practice" that “may foster misperceptions” of our altruistic intentions.

This strategy has the additional advantage of allowing us to save face if we find it necessary to give up other forms of bribery in the future, such as free meals and free textbooks.

Q: You’ve thought of everything! I’ll be sending in my 2009 PhRMA dues early in appreciation of all your good work.

A: We aim to please.