Interactions with Healthcare Professionals: 6 Essential Compliance Principles

What principles should pharmaceutical companies follow when interacting with Healthcare Professionals (HCPs) and Healthcare Organizations (HCOs)?

Introduction

Every pharmaceutical company inevitably interacts with healthcare professionals (HCPs) and healthcare organizations (HCOs). These interactions may be grounded in legitimate purposes such as scientific consultancy, clinical research, educational support, or charitable donations.

However, if not properly structured, they can expose companies to ethical vulnerabilities, legal risks, and public trust issues. In this article, I share six key compliance principles based on my direct experience in the field.

1. Legitimacy: "What is the true purpose of this interaction?"

All engagements must serve a clear, legitimate scientific or legal purpose. Activities, support, or invitations aimed at HCPs or HCOs should be based on objective needs. Otherwise, they may be perceived as disguised promotional efforts or incentives.

Experience note: In the past, it was not uncommon for companies to provide personal gifts to physicians — items like mobile phones or household appliances were frequently seen, particularly in local practices. Today, however, both national regulations (such as TİTCK in Turkey) and industry codes clearly prohibit such practices. Gifting is no longer just ethically questionable — it is outright non-compliant.

2. Transparency: "Would this support be defensible if made public?"

All interactions with HCPs and HCOs must be managed transparently. Companies should design grants, sponsorships, or consultancy arrangements in ways that are easily explainable — internally and externally. Even in countries where public disclosure is not mandatory, transparency remains a cornerstone of ethical responsibility.

3. Documentation: "If it’s not written, it didn’t happen."

Verbal agreements present significant compliance risks. Especially in cases involving donations or other forms of value transfer, it is critical to obtain clear documentation demonstrating that the request originated from the institution. Examples include:

• A formal written request from the HCO

• Transfer of Value (ToV) documentation

• Inventory registration showing receipt of any donated goods

• The purpose of the donation must be clearly stated — supporting education, improving healthcare delivery, or contributing to patient care. It is essential to remember that donations are contributions made to support activities in the public interest, without receiving anything in return. Donations to individuals are strictly prohibited.

Likewise, all collaborations with HCPs — including consultancy and speaking engagements — must be governed by written contracts, in full alignment with applicable laws and internal company policies. Compensation must be based on Fair Market Value (FMV), and payments must be transparent, justified, and documented.

4. Know the Boundaries: "Reasonable is acceptable; luxury is not."

When HCPs or HCO representatives are invited to an event or supported financially, details such as the venue, meal standards, and transportation arrangements matter. Hosting events at luxury locations or offering excessive hospitality may distort the purpose of the engagement. Contributions must always be reasonable, proportionate, and aligned with policy and regulations.

5. Promotional vs. Educational Content: "Are we informing or marketing?"

A clear distinction must be made between promotional activities and scientific education. When sharing information with HCPs, is the goal to promote a product, or to contribute to scientific knowledge? This distinction should be reflected in the tone of communication, the speaker profile, the materials used, and the format of the event.

Product promotion meetings are by nature promotional and include product-centered communication. Conversely, satellite symposiums held within scientific congresses may include product promotion — and must therefore be properly categorized and approved as such. Establishing this separation early in the planning phase supports both internal audits and regulatory scrutiny.

6. Local Compliance within Global Frameworks: "Global principles require local adaptation."

Many global pharmaceutical companies operate under internal policies on cross-border Transfers of Value (TOV). These frameworks help standardize donations, sponsorships, and consultancy agreements across countries.

However, true effectiveness requires alignment with local laws and practices. In Turkey, for example, the TİTCK Promotional Regulation and the Transfer of Value Guidelines provide strict rules on industry–HCP interactions. Similar frameworks exist elsewhere — such as the Sunshine Act in France and Open Payments in the U.S.

To ensure full compliance, local teams must be trained and regularly updated on both global and national requirements. Continuous education, internal communication, and monitoring are essential.

Coordination Between Compliance and Medical Functions

Scientific meetings, advisory boards, and insight-gathering activities are often led by medical departments, but compliance teams play a key enabling and safeguarding role. Effective coordination is especially needed in the following areas:

• Classifying presentations correctly and reviewing content accordingly:Promotional meetings, by design, involve product messaging. In contrast, scientific meetings, advisory boards, or patient education programs must avoid even the perception of promotion.For example, satellite symposiums held within scientific congresses may include product-specific discussions — making it critical to properly categorize and manage such formats.

• Ensuring scientific objectivity in speaker and participant selection

• Drafting and approving HCP contracts using FMV-based compensation

• Managing conflicts of interest and ensuring procedural compliance

Compliance teams support medical departments in staying within legal and ethical boundaries by reviewing content, defining activity types, and providing appropriate approvals. This collaboration helps uphold both compliance and corporate reputation.

Keeping Educational Content Truly Non-Promotional

Medical education events, disease awareness campaigns, and scientific knowledge sharing sessions can all risk being perceived as promotional if not carefully structured.

To avoid such misperceptions, companies should:

• Ensure content presents all treatment options, not just their own product

• Select speakers based on scientific credentials, not commercial value

• Use up-to-date data with referenced, evidence-based content

• Clarify the objective of the session and avoid any implicit incentives

• Require compliance approval and post-event review where applicable

These practices not only enhance the educational value but also help build transparency and trust.

Conclusion: Compliance Should Be a Reflex, Not Just a Rule

Interactions with HCPs and HCOs reflect a company’s culture as much as its procedures. Compliance teams may lead the process, but everyone — from commercial to medical — plays a role in protecting the company’s integrity.

Before every engagement, it’s worth asking:“If this interaction were published on our intranet homepage, would I be comfortable with it?”

This article is based on professional experience in the pharmaceutical industry and does not reference any specific company or project.