Doctors – supposedly the “victims” of the pharmaceutical industry's promotional excesses and "sophisticated" persuasive techniques – will be the biggest losers under new requirements of the Australian Competition and Consumer Commission (ACCC) for greater levels of disclosure and transparency in relation to pharmaceutical company sponsorship, announced yesterday. (The ACCC authorises the industry self-regulatory code developed and administered by Medicines Australia.)
In fact, pharmaceutical marketers may actually benefit from closer public and regulatory scrutiny of their spending on entertainment for doctors, but doctors will be further disadvantaged if sponsorship of prescriber education is reduced as a consequence. But the bottom line is that the changes are likely to have no discernible effect on the health and welfare of consumers and the community as a whole.
There have certainly been some excesses in terms of pharmaceutical entertainment and largesse in the past... and I've been to some fairly lavish affairs put on by drug companies (and usually wound up asking myself why they were bothering). But, from a marketing perspective, many promotional practices viewed in the pharmaceutical industry as ‘the usual’ or ‘cost of entry’ are actually undertaken without any evidence of their marketing effectiveness.
Just because companies do something doesn’t mean it works... or, indeed, that it is harmful to the health of individuals or the community. Many of those urging the ACCC to impose tighter controls on the activities of pharmaceutical companies don’t cite any evidence that promotion actually has harmful effects on the attitudes or behaviour of prescribers.
In many cases, it's possible that cutting back on largesse might actually enhance pharmaceutical company profitability by reducing wastage. Drug companies should be ensuring that they invest their marketing dollars where they will be most effective. In the spirit of value-based marketing, the industry should probably look at this new requirement for transparency as an opportunity – it may well force greater internal scrutiny and justification of some of the "traditional" lines on their marketing and promotional budgets.
But the whole issue of further regulation leaves a bitter taste for doctors. Firstly, any increase in scrutiny inevitably raises implications about the perceived intelligence and integrity of prescribers. This type of regulation sends an unequivocal signal to the community that the ACCC feels doctors cannot be trusted to evaluate clinical and scientific evidence for themselves or, at worst, to behave ethically when selecting treatments.
The underlying message is that the regulator we trust to protect us as consumers – egged on by lobbyists such as the Australian Consumers Association (ACA) – believes that a doctor might put his or her own interests ahead of those of the patient for the price of a restaurant meal and half a bottle of wine. If you think I'm being melodramatic, check this out... In a submission to the ACCC, Prof Ken Harvey of La Trobe University argues for tougher regulation of pharmaceutical promotion not on the basis of evidence but on the astonishing assertion that pharmaceuticals are like tobacco and alcohol, and that any “highly profitable industries which spends (sic) a large proportion of their earnings on sophisticated promotion all encourage overconsumption and unhealthy habits”.
Secondly, prescribers are still expected to act as agents and "gatekeepers" for the Government in administering the Pharmaceutical Benefits Scheme (PBS), a role for which they are completely unremunerated, while what minor compensations there might be for undertaking this role are whittled away.
The PBS is a massive program under which Australian consumers get extraordinary access to the world’s best and latest drugs. Yet doctors are expected to spend their own time and resources keeping themselves up to date with the intricacies and fine print of PBS listings, which change every three months. Even the most strident advocates of centralised regulation of pharmaceutical promotion acknowledge the reality that doctors remain reliant on the pharmaceutical industry for information about new drugs and changes to PBS listings and requirements.
QBrand's own experience conducting research with hundreds of GPs and specialists confirms that doctors take this gatekeeping role extremely seriously if grudgingly. Yet in no other sector of Australian society would professionals be expected to fulfil such an agency role without some form of consideration or compensation... like the occasional dinner and a drink!