Central Database Working Group
A Centralised Reporting System for Medicines Australia Member Companies’ Payments and Transfers of Value to Health Care Professionals
On 24 April 2015 the ACCC issued its final determination granting conditional authorisation of Edition 18 of the Medicines Australia Code of Conduct for a period of five years. The authorisation became effective on 16 May 2015.
A condition of the authorisation is that Medicines Australia must use reasonable endeavours to develop and implement a Central Reporting System (CRS) which will allow the public to access information on payments and transfers of value from all companies to healthcare professionals in a single location, via the internet. This condition also requires Medicines Australia to provide regular six-monthly reports identifying the steps taken each reporting period to develop and/or implement a CRS.
Establishing a Centralised Reporting System
Since the sixth progress report published in May 2018 we have undertaken the following work.
Medicines Australia finalised contracts with Pacific Commerce Pty Ltd in late May 2018 to develop and build the CRS in accordance with the specified requirements. Necessary scoping and planning activities have been conducted by Medicines Australia and Pacific Commerce. The technical build of the system has commenced. The CRS is currently on track to include data from the reporting round of 1 November 2018 – 30 April 2019, which will be published in August 2019.
In conjunction with the technical build of the CRS, Medicines Australia is also currently considering issues concerning the collection notices and verification statements used by member companies when engaging with healthcare professionals. Medicines Australia recognises that the collection statements used during the informed consent phase and the early stages of the reasonable expectations phase of reporting do not provide sufficient notice to healthcare professionals to allow any historic data to be included in the CRS. There are a number of healthcare professionals who have been engaged to conduct activities during the current reporting period (November 2018 – April 2019) that were contracted prior to revising the collection statement. These data will not be included in the CRS, but will be included in reports published on individual member company websites.
There also remains a small number of activities that were conducted during the informed consent period, for which some healthcare professionals opted out of reporting, but relevant payments might be made in the current reporting period. These data will not be included in the reporting system, but will be included in the reports published on individual member companies in aggregate.
Over time, Medicines Australia expects the CRS to represent a complete set of reporting data. However, due to the long lead times of many of these activities and the reporting timelines, it is not possible to immediately include all data on the CRS whilst ensuring handling of healthcare professionals’ personal information is consistent with Australia’s Privacy law.
Fifth Transparency Reports
Medicines Australia continues to spend considerable time and effort in assisting and advising member companies in preparing their information about reportable payments and transfers of value to individual healthcare professionals. The fifth reports, relating to activities occurring between 1 November 2017 and 30 April 2018 were published by member companies on 31 August 2018. Thirty-three member companies published reports on their company websites. These reports are hyperlinked from the Medicines Australia website.
This was the third, full six month reporting period where healthcare professionals reasonably expected their data to be published. As anticipated, there were still a small number of activities reported in aggregate. This is due to there being some healthcare professionals who were engaged by companies before 1 October 2016 who had not given consent for their information to be reported but the relevant payment was made during the last reporting period (November 2017 to April 2018). It is expected that these aggregated data will continue to phase out over the coming reporting periods.
The work of Medicines Australia and its members in the six months to November 2018 demonstrates significant progress in respect of the development of a CRS whilst delivering transparent reporting of payments and transfers of value to healthcare professionals for activities between May and October 2017.
Medicines Australia will work with its selected service provider to continue development of the CRS and testing that it meets all requirements prior to data being included or published by the system.
16 November 2018
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