Compliance Archives

Navigating the Meal Caps Maze: HINTS and TIPS from Healthcare Venues

by Mark Handforth | Nov 30, 2023 | Compliance, Experts, Meetings, Thought Leadership

It is not surprising that the question most asked of us at Healthcare Venues, as we do suggest we are subject matter experts, is: “Do you have a webpage that details all the international meal caps and other code detailed guidance for meetings by country” In short, NO! If we did that, we would need to employ at least another member of staff, full time, to keep on top of them, and remember, if every country has their own guidance there will be 195 country pages!

But don’t worry, there is a solution.

As we are about to share in our forthcoming 3rd Compliance Workshop, from the beginning of the pandemic in February 2020 to the “end”, c. 2 years later, there were no changes in European meal caps, and yes, that does include the UK! However, since then, we have seen 7 EFPIA (European Federation of Pharmaceutical Industries and Associations) scorecard updates reflecting more than 12 different country increases.

What exactly is so CHALLENGING?

For cross-border meetings i.e. HCPs (Healthcare Professionals) from different countries, despite codes of practice providing guidance that the host code could be applied, many healthcare companies apply the lowest (strictest) meal cap for all attendees or even their own fair market values, sometimes provided by the affiliates.
The European Regulator, EFPIA, does provide a ‘Scorecard for Meals and drinks’ but it’s hard for it to be always up to date. The current version is, at the time of publication of this article, from 22nd November 2023.
But country meal cap updates will not be reflected in the ‘current’ code of conduct which might date back a couple of years; however, you will find the detail within any updates/addendums.

HELP:

To start off, if you were working with EU meals caps (including the UK) HERE you can find the latest EFPIA scorecard, as mentioned above, but NOTE: if the link stops working, it means that it has been updated, again! So please, in this instance, check the EFPIA website.

Failing that, you know that Healthcare Venues will post any updates on our page on LinkedIn and the Healthcare Hub community pages, You are welcome!

For our Healthcare Venues, here is our solution in this month’s HINT and TIP, however, for agencies, it might also answer some questions:

HINT:

For hotels and venues, you MUST know what your national meal cap limit is – you are in the “host country”. This is typically included as part of our Venue healthcare Champion Training but if you are not part of our membership, click the EFPIA scorecard link above to find what national meal cap is. For non EU countries, please contact us.

Note: the rates shown are maximums! And even then, agencies should be considering the audience: can the level of hospitality be considered appropriate for a senior consultant, if so, it might not be considered appropriate for a nurse or newly qualified Doctor. And meeting stakeholders should consider whether the proportion of education in the agenda versus the level of hospitality is appropriate. Try the ‘red face’ test: would you be able to defend the choices made if the details of the event were made public?

Think about what menu packages you are sending along with your proposals, there is no point in sending dinner menu and drinks packages that exceed that limit, as selecting them would be uncompliant! “And no, we do not recommend that you should ‘create’ a room hire charge to enable you to reduce the menu price.”

Note: for venues who do typically charge a room hire for meeting and events, this would likely be acceptable, but note, some company policies may determine that room hire charges are included and spread across the number of attendees, thus making the per person cost exceed the meal cap.

TIP for our HEALTHCARE VENUES:

Create healthcare meal packages that comply with your national meal cap limit, or even better, less, as many company policies apply the lowest or strictest rate.

We all know the costs of human resources, energy and ingredients have increased due to inflation, so it makes sense to sit down with your chefs to create cost effective and compliant menus and drinks packages. If as is typical you send all your menus, with your proposal including an attractive package at 70 euros, don’t be surprised when you are asked to charge 60 euros.

IN SUMMARY:

Be proactive with your clients. Demonstrate your knowledge and suggest that whilst we have healthcare packages that respect the national meal cap limit.

We can and have shared with you where to find the scorecard for meals and drinks however, the potential stricter company policies are not open source, so be sure to ask what meal cap they are applying to this meeting.

AND FINALLY…….A WORD OF WARNING FOR MEETING VENUES. There is a current trend of employing DJs in hotel lobbies and bars, which might be fun for leisure guests and the local community seeking some extra atmosphere, but if your clients are looking to book HCP dinners in your restaurant, anything more than background music i.e., DJs, live music or anything else that might be considered entertainment, and is likely to be considered inappropriate.

Good luck and if you have any questions, please do let us know. For our next Hint and Tip, how about we tackle Star Ratings?

Click here to read more about the work of Healthcare Venues.

Winning Healthcare Meetings and Events: Why Understanding TOV is Non-Negotiable for Venues

by Simon Beard | Oct 20, 2023 | Blog, Compliance, Experts, Meetings, Resources

At Healthcare Venues we are regularly asked by hotels and venues this question: “How can we receive and convert more enquiries from the Healthcare sector?”

My first response is that if Healthcare is a target market, they have come to the right people, as we look to help in 3 ways. 1) Provide a sector specific listing on the Healthcare-Venues.com website with 2) an independent Compliance Index, and 3) deliver our Venue Healthcare Champion training course. Our post training Hints and Tips form just one element of skills training that takes learners, via a series of memorable methodologies, on a journey to become a venue’s Compliance Expert.

So, welcome to the first in a monthly series of Hints and Tips where we tackle some of the more challenging areas around the organisation of code appropriate Healthcare Meetings and Events.

The hints and tips are aimed at hotels and venues however, if you are a meeting planner and are tired of explaining what TOV is and why it is important, you might just want to share this with the venues you work with so they learn something new. Not for those venues, it has to be said, that are on our platform and have already been trained to understand and action!.

So why are we covering TOV first? Well, it’s because we are hearing from more and more corporate meeting specialists and agencies, that if a venue does not understand the importance of TOV, and support its reporting, they will be more likely to NOT want to work with the venue again!

I have split this hint and tip into the ‘Background’, so readers who don’t know the history can understand why the accurate reporting of TOV is critical and non-negotiable. The HINT, if you like, and then the TIP.

Background (Hint):

Let’s start with some history. In mid-2007, Australia was one of the first countries to require the reporting of details from every industry-sponsored event ₁

The US followed in 2010, and passed The Physician Payments Sunshine Act (now known as open-payments) to increase transparency of financial relationships between healthcare providers and pharmaceutical manufacturers ₂.This was the significant catalyst which started a global impact. I’ll focus on the European requirements in this article.

It was on 2nd July 2013, that EFPIA (the European Federation of Pharmaceutical Industries and Associations) announced the release of its disclosure code for transfers of value ₃ to healthcare professionals and organisations. It required its members to disclose transfers of value to HCP’s and HCO’s as of 2016 for all transfers made in 2015 either on their websites or, where available, on a national platform for disclosure.

Before this, companies were displaying the total amount being spent on meetings for doctors on their corporate webpages. Try a web search, you can access TOV reporting documents that are open source and open to scrutiny.

In 2016, healthcare companies in the European region now had to disclose payments made, directly or indirectly, to healthcare professionals (HCPs) for every event. relating to the following areas:

Accommodation: Bedroom only Rate
Catering: Breakfast, lunch, dinner, and coffee breaks
Travel: Plane, train, car, or coach transfers
Congress registration: Registration Fees

This action was aimed at satisfying the increasing need to demonstrate transparency in the relationships between the healthcare industry and healthcare professionals.

We are now in its 7th year, and we know the data being captured is far more extensive than the EFPIA template and, in most cases, it is the project planner that is responsible for collating all this data in a timely manner and it MUST be accurate. You can expect that for a meeting for 100 healthcare professionals, there is in excess of 40,000 pieces of data requiring validation and capture.

This all sounds reasonable and logical, and for us, as patients, it makes for very interesting and reassuring reading. However, the practicalities of delivering such large amounts of data are, like compliance, never straight forward and are time consuming. So, how can you, the venue, help?

The Tip

We are all “BUSY” and Meeting planners are more so, and they tell us that if a hotel or venue does not understand TOV, and needs education on what it is, then they are far less likely to want to work with them. This is one area that is non- negotiable for the planner, and a significant part of their role.

So, for ANY hotel or meeting venue, not just those on the Healthcare Venues platform, that wishes to convert more business, you must understand the following:

360 Healthcare Venues Winning Healthcare Meetings and Events Why Understanding TOV is Non-Negotiable for Venues The Tip

You must be able and prepared to break down your bundled rates, e.g., B&B or DDR rates.
Invoicing must be clearly presented in the format your client requires, it may be slightly different from company to company.
You must be able to do this within the requested time frame.

Note: Meeting organisers are not trying a tactic to unpick the profit margin within a DDR, but as you can now see, it is to make sure they can complete their report accurately.

It really is that simple, and it’s the same for any client you are trying to win or retain. Understand your client, their pain points, and if you can make their lives easier, they are far more likely to be a ‘returning customer’, plus they will also spread the word of your excellence to colleagues and their broader network.

1 journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1000128

2 openpaymentsdata.cms.gov

3 www.efpia.eu/relationships-code/disclosure-of-payments

Educational Visit: with growing event agency Activate and Healthcare sector specialists Park Plaza Hotels

by Mark Handforth | Dec 12, 2022 | Compliance, Experts, Meetings, News, Venues

Educational visits are brilliant … one of our favorite interactions. Education and a bit of fun in a package. Bringing meetings partners together in a high-value engagement.

Outcomes:

Instruct new team members in the growing Activate business on the fundamentals of healthcare compliance, using case studies to deliver content that is aligned with the company’s role.
Incorporate Park Plaza healthcare meetings capability solutions into training content, ensuring alignment with key meeting types and operational best practices.

Thank you Simon & Patrick for taking the time to come and visit us. We really appreciated the insight and learning gained from the compliance training and the updates on Park Plaza Hotels – and yes, it was a lot of fun!

Ken Carter
Client Services Director –Activate Events

It was great to be back in the Activate Events office with Healthcare Venues. The interactive sessions that Simon runs are a great and unique way of building rapport with our clients, whilst developing our knowledge of compliance and how it’s applied in the pharmaceutical events world

Patrick Brady
Account Director – Park Plaza Hotels Europe

These sessions are all about ROI. Refresher training for the experienced and baseline training for those new to meeting compliance. Sponsors engage with their clients through a shared learning experience and we all have fun being part of it

Simon Beard
Compliance Consultant – Healthcare Venues

Want to hear more about our Educational Visits and how they can help your business contact us for more information.

About Activate Events

We are not an agency with ready-made answers. Instead, we are a team of professional event strategists and planners who know better, who care, and who try harder than most. Together, we design experiences from concept to implementation. It is fair to say that we have a genuine ‘go above and beyond customer service ethos, but we are also a hugely unassuming organisation. This mentality fuels our hunger to be the best, and thus serves you as well as us. It is why we apply an almost forensic attention to detail in our proposals and the execution of our events. It is why we are agile, anticipating potential obstacles and diffusing them before they turn into real problems.

About Park Plaza Hotels

Park Plaza hotels offer contemporary-styled hotels, focusing on meetings and events in flagship properties located in city centre locations.

About 3Sixty Event Consulting

Whether you’re a corporate healthcare organisation, an agency, meeting venue, destination or medical society, we’re the independent, intelligent connection you’ve been looking for to navigate the complexities of the healthcare meetings sector. Our experts will help you master the healthcare meetings matrix, linking you with the movers and shakers of the sector, collaborating on best practice, sharing cutting-edge thinking, and providing expert strategy support and training in compliance, meeting design and delivery. Bringing healthcare meeting communities together in an interactive eco-system of best practice, and better healthcare meetings throughout the product lifecycle.

About Healthcare Venues

Healthcare Venues is an innovative meeting planning solution for meetings and events in the healthcare sector. Use the venue’s rigorous, independent compliance assessment for meeting approvals, work with trained specialists when planning your meetings, and consider the venue’s capabilities for meetings specifically for the healthcare sector.

French Anti Gift Law: for Meetings and Events

by Mark Handforth | May 25, 2022 | Compliance, News, Resources

Date: Thursday 19th May 2022

Expert: Laurent Clerc, Head of Compliance Clardian

The market leader in software dedicated to compliance and regulatory process optimization. Clardian offers health industries various SaaS solutions to comply with the regulations and standards of today and tomorrow.

Kindly supported by MedCommsNetworking.com

This global initiative facilitates networking and dialogue amongst individuals working in and around the pharmaceutical industry and MedComms, focusing on specialist medical education, medical communications and medical publishing activities.

Moderator Mark Handforth 3Sixty Event Consulting

“In this webinar we attempted to simplify and apply the French Anti Gift Law to meetings and event. If you are working as industry or a 3rd party with healthcare professionals whom gain “advantages” specifically financially this webinar is for you – we hope you enjoy it.”

If you wish to keep ahead of similar webinars and content join our community by clicking here and adding your email into the subscribe box.

Part 1 of the webinar: The French Anti Gift Law for Meetings and Events

The French Anti Gift Law as it is applied to meetings and the approval of costs related to the financial relationships between (French) Healthcare professionals and industry.

Laurent explains the scope of the law, process and timelines, to whom it applies and what information is required to make a submission

What are the (financial in/out of scope) “Advantages”: 9mins 15sec
Application website URL’s: 14mins 28sec
Financial thresholds: 18mins 57sec

Part 2 of the webinar: The French Anti Gift Law for Meetings and Events

MEETING SCENARIOS

In this section we concentrate on 3 specific scenarios and explain how the law applies;

French HCP’s attending a meeting
A company booking an exhibit booth at a French medical meeting
Payment of honoraria for a French KOL to speak at a meeting / webinar

Part 3 of the webinar: The French Anti Gift Law for Meetings and Events

In this section we tidy up burning questions and clarifications including;

Q&A and WEBINAR SUMMARY

How to handle approval submissions when you cannot forecast the financial “advantages”
The role of 3rd parties in making submission
Checking submission status
Educational grants

Industry bodies issue guidance on virtual and hybrid meetings by medical societies

by Mark Handforth | Apr 26, 2022 | Compliance, Experts, Meetings, News

IFPMA, EFPIA and PhRMA have updated their joint guidance for virtual medical society meetings

The guidance, focused on medical society virtual / hybrid meetings can be seen here in more detail with a Q&A document here.

3Sixty thoughts:

More very welcome guidance upgraded since the 2020 issue now including Hybrid meetings which are expected, by industry and societies, to be the dominant form of “congress” moving forward.

What caught our eye?

1. The new (ish) IFPMA ethos was reinforced in the document. Why do we think this is important? Well, the Ethos outlines a code based not solely on rules but one framed in; integrity, values and principles. The result? more subjective decision making o identify is something the right thing to do! If your organisation has not already defined how this impacts the part you play in the creation and planning of meetings and ensured your teams are ready then you’re behind the game …

2. Guidance is applied to international meetings, defined as medical associations/societies involving HCPs from multiple countries. National meetings are not “in-scope” we tend to use the Congress Vetting System (CVS) criteria when determining what is a national and international medical society meeting.

3. The code (international, regional or national) still applies even if they were written with in-person meetings in mind. Note sections on an events educational value, medicine promotion, certification (see ABPI clause 8 to see how the UK handles this), destination and venue selection in the case of in-person formats as a few examples of how to still apply the code. Reminder, every meeting supported by industry must include a written rationale outlining the reason industry is supporting a meeting in the rush to plan the tactic this can be overlooked.

4. The route to apply the right code and label to a meeting has been strengthened, reminding industry not to rely on medical societies / congresses to determine the applicable code to a meeting but to take that into their own hands. This is another reason why there should be a stronger link during planning between medical societies, industry and PCO’s pooling knowledge and communicating as a collective how the code applies to meetings.

MedTech Europe and EFPIA merge medical society congress vetting / assessment platforms

by Mark Handforth | Feb 22, 2022 | Compliance, Meetings, News

MedTech Europe and EFPIA merge medical society congress vetting / assessment platforms

events One of the significant features of healthcare and life science regulation is the need of those business partners, not directly guided by the code, to recognise that the code in a collateral way may impact them.

One such example is the vetting or assessment of independent Medical Society congress activities using metrics derived from the code.

Back story

For a number of years congresses have been vetted or assessed if you prefer, via independent solutions and platforms by both European trade / industry / regulatory bodies.

Medical devices – MedTech Europe, Platform: CVS

Healthcare and life sciences (pharma) – EFPIA, Platform: e4ethics

Criteria differed between both organisations with some common threads.

What’s different?

Since 01 January 2022

The MedTech Europe (cvs) and EFPIA (e4ethics) platforms have now merged to be focus applications through the MedTech Europe platform.

MedTech Europe Application Website

So, what does this mean in more tangible terms?

Both platforms operate independently from EFPIA and MedTech Europe, via a common Compliance team, to ensure objectivity and independence in conference assessments.
e4ethics is aligned with the CVS criteria and approach, including the online proactive submissions by companies or congress organisers (Professional Congress Organisers as well as scientific societies).
The submission procedure and appeal process is identical for both systems.

The type of Events qualifying for review will remain different

For Events assessed under e4ethics, only those that qualify as major international Events taking place in the countries within the scope of the EFPIA Code, (Europe) will be reviewed. Events in which Healthcare Professionals coming from more than 5 countries may take part and which are expected to attract a significant number of participants (at least 500), will be considered (that means meetings outside Europe too) .

On the other hand, within the CVS, international Events need to be reviewed when they are taking place within the MedTech Europe geographical scope. This includes:

- Events attended by delegates coming from at least two countries of MedTech Europe geographical scope; and
- Events taking place outside the MedTech Europe geographic area, attended by delegates who are HCPs registered and practicing in the MedTech geographical area.

How do I learn more about the vetting / assessment solutions?

Information on MedTech Europe, CVS approach: Link

Information on EFPA, e4ethics approach: Link

Note: the comments within this bog post are those of 3Sity Event Consulting – we recommend viewing the links provided before using this information to execute any business decisions.

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