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Table 2 Non-R&D payments subject to disclosure under the JPMA Transparency Guidelines and the ABPI Code

From: International comparison of pharmaceutical industry payment disclosures in the UK and Japan: implications for self-regulation, public regulation, and transparency

JPMA Transparency Guidelines (2018)

ABPI Code (2019, 2021)

Payments

Recipients

Mode of disclosure

Payment description

Payments

Recipients

Mode of disclosure

Payment description

Scholarship donations (B1)

HCOs

Named recipients

Donations to universities and research institutions for research and educational programs (Chapter 5, 3, Publication Subject, B, Academic research support expenses.)

Donations and grants

HCOs

Named recipients or aggregate recipients depending on recipient consent (starting from 2019—only named recipients)

"Medical and educational goods and services which enhance patient care, or benefit the NHS and maintain patient care" (AC2019, Clause 19.1–2). Replaced by donations (“physical items, services or benefits-in-kind)” and grants (“provision of funds”) (AC2021, Clause 1.5, 23.1)

General donations (B2)

Donations to non-profit organizations and incorporated foundations to support their operations (Chapter 5, 3, Publication Subject, B, Academic research support expenses.)

Donations to academic and other societies (B3)

Donations to professional medical societies to support their operations (Chapter 5, 3, Publication Subject, B, Academic research support expenses.)

Expenses related to co-sponsored conferences (B4)

Named recipients

Expenses made to host luncheon, seminars and symposiums in conferences hosted by professional medical societies (Chapter 5, 3, Publication Subject, B, Academic research support expenses)

Contributions to costs of events

HCPs and HCOs

Named recipients or aggregate recipients depending on recipient consent (only HCPs)

Organisational-level sponsorship agreements and individual-level registration fees, costs of travel, and accommodation (AC2019, Clause 22.5, 24.2). Replaced by “sponsorship” of events/meetings (organisational-level payments) and “support” of HCPs to attend events/meetings (individual-level payments), both of which can be “professional, promotional, scientific and educational” (AC2021, Clause 1.22–3, 10). Examples include “congresses, conferences, [and] symposia” (AC2021, Clause 1.7)

Expenses for lecture conferences (D1)

HCPs

Aggregate recipients

Expenses to organize conferences and symposiums for drug promotion, such as travel fees, and venue, meal, and reception costs (Chapter 5, 3, Publication Subject, D, Information provision-related expenses.)

Lecture fees (C1)

Named recipients

Compensation to physicians for writing endeavours to other healthcare professionals, directly paid to writers (Chapter 5, 3, Publication Subject, C, Manuscript/writing fees, etc)

Fees for service and consultancy

Organisational-level "contracts between companies and institutions, organisations or associations of health professionals" (AC2019, Clause 21) and individual- or organisational-level “fees to consultants …, or to their employers on their behalf, for certain services … such as chairing and speaking at meetings, assistance with training and participation in advisory boards” (AC2019, Clause 23.2)

Manuscript writing fee/supervising fees (C2)

Compensation to physicians for advice and expertise to promote a particular medical product on the market, directly paid into the pocket of physicians (Chapter 5, 3, Publication Subject, C, Manuscript/writing fees, etc

Consulting/commissioning fees (C3)

Compensation to physicians for speaking, training, and educational endeavours to other healthcare professionals, directly paid to lecturers (Chapter 5, 3, Publication Subject, C, Manuscript/writing fees, etc

Other expenses related to academic research support expenses (B5)

HCOs

Named recipients

No descriptions available

No corresponding ABPI payment categories

Other Information provision-related expenses (D4)

HCPs

Aggregate recipients

Explanation meeting expenses (D2)

Expenses to organize study seminars for drug promotion (Chapter 5, 3, Publication Subject, D, Information provision-related expenses.)

Payments for food and drink below £75 (100$) per head are excluded from disclosure requirements. Higher payments are prohibited (AC2019, Clause 1.10, 22.1–2)

Expenses for provision of literature and other products (D3)

Expenses for articles and documents in medicine/pharmacy, and advertising products such as pens and calendars (Chapter 5, 3, Publication Subject, D, Information provision-related expenses.)

“[I]nexpensive notebooks, pens and pencils for use at [company organised scientific] meetings” with value less than £6 per head excluding Value-Added Tax (AC2019, Clause 1.10, 18.3) are not disclosed

Other expenses (E)

HCOs and HCPs

Aggregate recipients

Expenses for hospitality, etc. as social courtesy (Chapter 5, 3, Publication Subject, E, Other expenses.)

No corresponding ABPI payment categories

No corresponding JPMA payment categories

Joint working (replaced by collaborative working)

HCOs

Named recipients or aggregate recipients per company depending on recipient consent (starting from 2019—only named recipients)

"Situations where, for the benefit of patients, one or more pharmaceutical companies and the NHS pool skills, experience and/or resources for the joint development and implementation of patient centred projects and share a commitment to successful delivery" (AC2019, Clause 20). Subsumed under “collaborative working”, covering “initiatives which either enhance patient care or are for the benefit of patients or alternatively benefit the (…) NHS and, as a minimum, maintain patient care” (AC2021, Clause 20.1, 20.4)

Contracted services (data disclosed starting from 2023)

Members of the public including patients and journalists

Aggregate recipients per company and recipient category

Consultancy “services such as speaking at and chairing meetings, involvement in medical/ scientific studies, clinical trials or training services, writing articles and/or publications, participation at advisory board meetings, and participation in market research where such participation may involve remuneration and/or hospitality” (AC2021, Clause 24.1)

  1. Unless stated recipient categories from the 2019 ABPI Code are the same in the 2021 version of the Code
  2. HCPs Healthcare professionals, HCOs Healthcare organisations, NHS National Health Service in the UK