by Hein Smit Sibinga and Wade Speir of PA Consulting Group
The new PhRMA and AdvaMed Codes of Ethics on Interactions with Health Care Professionals have received a great deal of attention, focused on the particulars of the various rules which will, no doubt, be interpreted by industry and in the courts for years to come. However, a crucial passage in the AdvaMed code, which “encourages” companies to follow the seven elements of an appropriately tailored, effective compliance program has not received due attention. It focuses on the importance of building the crucial governance required to be able to comply in an effective and efficient manner – a lesson still being learned in many others areas of the pharmaceutical business.