Voluntary Disclosure Of Payments
Open by design. Our members publicly disclose transfers of value to healthcare professionals, so Canadians can see exactly how our industry operates.
As part of our commitment to high ethical standards and enhancing trust, Innovative Medicines Canada has developed a Voluntary Framework on Disclosure of Payments made to healthcare professionals and organizations in exchange for services, and to fund charitable, educational and scientific activities.
Collaboration between healthcare professionals, healthcare organizations and the pharmaceutical industry is essential to improving the quality of life of Canadians, as such collaboration drives scientific advancements, enhances medical education and promotes health literacy.
In June 2017, Innovative Medicines Canada developed a framework to support member companies who choose to publish aggregated sums of payments to Canadian healthcare professionals (HCPs) and healthcare organizations (HCOs) based on the following reporting framework:
- One sum total of the company’s payments to HCPs for services such as speaking and/or consulting.
- One sum total of the company’s funding to HCOs, which supports efforts such as philanthropic (charitable), educational and/or scientific activities.
- One sum total of the company’s funds provided to HCPs to support their travel to attend international congresses and/or global standalone meetings.
At that time, there were 10 companies who voluntarily disclosed payments:
- AbbVie Corporation
- Amgen Canada Inc.
- Bristol-Myers Squibb Canada
- Eli Lilly Canada Inc.
- Gilead Sciences Canada, Inc.
- GlaxoSmithKline Inc.
- Hoffmann-La Roche Limited (Roche Canada)
- Merck Canada Inc.
- Novartis Pharmaceuticals Canada Inc.
- Purdue Pharma (Canada)
Innovative Medicines Canada does not collect any payment information from members. Member companies who continue to voluntarily disclose payment information publish directly to their own websites.
Voluntary Framework on Disclosure of Payments
The Voluntary Framework on Disclosure of Payments provides members of Innovative Medicines Canada with a framework to publish aggregated sums of payments to Canadian healthcare professionals (HCPs) and healthcare organizations (HCOs).
Scope
IMC considered the types of activities and categories where member companies would disclose aggregated payments. We decided that disclosure would take place in the following areas:
This applies to any direct or indirect payment made to a Canadian HCP by a Canadian Innovative Medicines Canada member company, or third party acting on behalf of the member company, in exchange for services rendered by the HCP to the Canadian member company. Services may include those rendered as a speaker, consultant or advisor to the Canadian member company.
Consistent with the current Code of Ethical Practices, an HCP is defined as, “… a person who by education, training, certification, or licensure is qualified to and is engaged in providing healthcare. This can include any of the following: an individual who is currently practicing medicine, nursing, or dispensing medicines in Canada or any other person who, in the course of his or her professional activities, may prescribe, recommend, or administer a prescription medicine or be involved in related treatment or disease management.”
For greater certainty, a direct or indirect payment to a Canadian HCP payment is defined as:
- a payment to the HCP as an individual
- a payment to an HCP’s incorporated name or business name for services rendered by that HCP
- a payment indirectly to the HCP through a third-party intermediary
- a payment made to a healthcare organization for services rendered by an HCP associated with or employed by the healthcare organization
Member companies should be prepared to disclose the aggregated totals of fee for service. Depending on the member company’s system and reporting capabilities, these totals may or may not include applicable taxes as well as related incidental expenses.
Member companies are encouraged to include explanatory notes on their respective websites to describe and explain the amounts disclosed. For instance, a member company whose systems do not allow the extraction of applicable taxes may include an explanatory note to the effect of, “*taxes included.” Payments made for services, as defined here, rendered by a Canadian HCP for an international affiliate of the Canadian member company, would not be considered in scope for this framework.
This applies to direct or indirect provision of funding to an HCO for the purpose of supporting efforts related to, but not limited to, charitable, educational and scientific activities. For the purpose of this framework, an HCO is defined as a private or public sector organization, institution or association that is composed of HCPs and/or provides healthcare services (e.g. hospitals, primary care organizations, hospital foundations, HCP organizations and universities).
This provision of funding excludes:
- funding resulting in a purchase/exchange of goods or services, such as commercial booths or business to business/partnership agreements
- all funding related to clinical trials
- payments made to a Canadian HCO for services rendered by an HCP and which have been disclosed under category 1, “Fee for healthcare professional services/transfer of value to Canadian healthcare professionals”
This applies to a direct or indirect provision of financial assistance to a Canadian HCP for the purpose of attending an international congress (as permitted under section 10.2 of the Code of Ethical Practices). Such funding is intended for expenses related to travel, accommodation, meals and congress registration fees (as permitted by the Code) and does not include any honoraria or fee for service.
