by Michel A. Dutrée

Engage all the stakeholders when setting up financial disclosure registers

As EFPIA’s members prepare to make public disclosure of payments to healthcare professionals, Michel Dutrée, Director General of Nefarma describes how the Dutch industry association has taken a lead in establishing a central register, and offers his insights on the process

The first move to set up a central register for the disclosure of payment from pharmaceutical companies to healthcare professionals in the Netherlands happened in 2009, when former Minister of Health Ab Klink made a speech to mark the 10th anniversary of Code Geneesmiddelenreclame Foundation (CGRCGR), the organisation responsible for overseeing the code of practice in advertising pharmaceuticals in the Netherlands, in which all relevant stakeholders participate.

In his speech, Mr Klink discussed the lead-up to the passing of the Sunshine Act in the US, and suggested that rather than creating a legal requirement, the Dutch Government would prefer a system of self-regulation.

“It was all done in a collegiate way. Nefarma had collaborated with the Ministry of Health over ten years of the CGR, and we set up a team with the direct involvement of all the stakeholders to take things forward,” Dutrée said.

There followed discussions on how to structure the register and whether disclosure should be handled by individual member companies, or brought together on a single platform.

“We had invested over ten years, within the framework of CGR, in a multi-stakeholder approach, and decided it was important not to act unilaterally, but to get the direct involvement of doctors,” Dutrée said.

The Royal Dutch Medical Association, representing healthcare organisations, already had a working system called Gaia, supporting its professional accreditation system. “The Association pointed out that doctors were already familiar with Gaia, and suggested the financial disclosure register could be implemented on it,” Dutrée said.

The Ministry of Health agreed with the suggestion, and also agreed to pay start-up costs, with the CGR and Nefarma members companies paying for the maintenance of the register.

The modules were bolted onto Gaia and tested in 2012, leading onto the launch of the register and the first publication of financial transparency data in April 2013.

“We were the first mover in national financial disclosure,” Dutrée said.
“Others were thinking about it, but we did it.
We had more than 15 years of multi-stakeholder engagement
and this was the key to the whole process.”

The first version of the register, published in April 2013, itemised payments to the value of €32 million. Dutrée said there was concern that the media would use the information to cause embarrassment. The sting was drawn by the Director General of the Ministry of Health, who explained the benefits of transparency at the press conference held at the launch of the register.

“There was only one negative article in the press, the rest of the coverage just said the transparency system has arrived,” said Dutrée.

On the day of the launch there were 33,000 hits on the website, now there are around 600 per week. “Everyone was curious, but soon the novelty was gone. When we published the second edition in April 2014, there was only one newspaper article, and that said ‘Look, there’s no change,’” Dutrée said.

Based on Nefarma’s experience, Dutrée offers the following advice:

  • Team up with doctors and other healthcare professionals early on in the process;
  • Do not under-estimate the amount of work you – as an association – need to do. All the information must be thoroughly checked, and all member companies must be aligned to ensure data inputs are consistent;
  • See if it is possible to piggy-back an existing ICT platform that is already used by doctors – adding additional functions is easier than setting up a new platform;
  • Persevere it may be three steps forward and two back, but eventually you will succeed, Dutrée concluded.
Michel A. Dutrée is general manager of NEFARMA. He is a Board member of VNO-NCW (The Confederation of Netherlands Industry and Employers), Council member of IFPMA (World association of the Pharmaceutical Industry) and member of Executive Committe of EFPIA  (European association of the Pharmaceutical Industry).