Section 14: Transparency Reporting

1. Transparency reporting is a public benefit which provides visibility for consumers of payments and transfers of value made by Australian Companies:
   1. to Australian healthcare professionals who are engaged in patient care;¹
   2. as a sponsorship of a third-party organisation to conduct educational activities for Australian healthcare professionals who are engaged in patient care;²
   3. as a grant or donation to a healthcare organisation; and
   4. to patient organisations to deliver valuable services to Australian patients.³
2. Reports on these activities must be published in accordance with the Schedule stated in this Code, using the templates contained in the Code Tool Kit. Companies may also make these reports available on their overall corporate or Australian corporate website.
3. An authorised Company representative will provide to Medicines Australia, within seven calendar days following submission of each required report, a declaration that the relevant report includes all payments and transfers of value required in this Code.
4. The information disclosed in these transparency reports must be publicly available for three years from the date of first publication.
5. Companies are only required to report payments or other transfers of value that are related to prescription medicines. Companies that have separate operating divisions that do not supply prescription medicines for human use (for example, animal health divisions) are only required under this Code to report payments to healthcare professionals related to prescription medicines.
6. Companies must comply with Australian Privacy legislation regarding the reporting of individual healthcare professional data. Each Company must establish a means to ensure maintenance of records which comply with Australian Privacy legislation.

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14.1 Transfers of Value to Healthcare Professionals

Healthcare professionals provide the pharmaceutical industry with valuable, independent and expert knowledge derived from their clinical and management experience. This expertise contributes towards quality use of medicines and improved patient care.⁴

1. It is reasonable for healthcare professionals to be fairly compensated for legitimate expertise and services provided to the industry, and that such compensation be publicly disclosed by the pharmaceutical industry.
2. Transfers of value to healthcare professionals that must be reported are:
   1. Fees paid to healthcare professionals in return for speaking at an educational meeting or event;
   2. Fees paid to healthcare professionals in return for consultancy or advisory services;
   3. Any remuneration or sponsorship of a healthcare professional as described in this Code. This does not include payments to consultants in relation to research and development work, such as the conduct of clinical trials.
   4. Any airfare, accommodation or registration fees directly associated with a meeting, consultancy or advisory service (whether held within or outside Australia); and
   5. Fees paid to healthcare professionals for the purpose of market research only where the identity of the healthcare professional is known to, or becomes known by, the Company.  Reporting is not required where the Company contracting the market research is not involved in the selection of participating healthcare professionals and is not aware of the identities of those participating in the market research.
3. Reporting of all individual payments and transfers of value for each healthcare professional is required, indicating only the following information:
   1. date of the event or provision of service;
   2. healthcare professional’s name;
   3. type of healthcare professional;
   4. healthcare professional’s principal practice address;
   5. description of the service;
   6. description of the event;
   7. whether the payment was made to the healthcare professional or a third-party; and
   8. the amount of the payment or transfer of value subdivided into (where relevant) registration fees, travel and accommodation, and fees for service.
4. Where healthcare professionals request a payment for any of the above to be made to a third-party, these payments must still be disclosed for the individual healthcare professional, however, the report should identify that payment was made to a third-party. For the purposes of these reports, a healthcare professional is considered to have directly received the transfer of value of any registration fee, air travel or accommodation. Therefore, these transfers of value should be disclosed as being received by the individual healthcare professional, and not as a payment to a third-party. 
5. Companies will provide the opportunity to review and submit corrections to the information. Healthcare professionals should have a period of at least six weeks to review, verify or correct collected information about payments and transfers of value.
6. Companies must not make a transfer of value unless they have taken appropriate steps to give notice of this disclosure obligation, so that the healthcare professional would reasonably expect the disclosure.
7. It is not the intent of transparency to capture or report payments or transfers of value to healthcare professionals that arise through the individual’s employment by a Company.
8. Reports will be published in a central reporting system, Disclosure Australia, which will be searchable and downloadable in a format compatible with database management systems. 
9. Reports will remain available for three years from the date of first publication.

14.2 Sponsorship of Third-Party Educational Meetings  and Grants and Donations to Healthcare Organisations

It is reasonable for the pharmaceutical industry to financially support the education of healthcare professionals through sponsorship of meetings and symposia organised by third parties, and that such support is publicly disclosed.  It is also reasonable for the industry to provide a grant or donation to a healthcare organisation in accordance with Section 5.2.

1. Each Company will provide a report to Medicines Australia on all sponsorships of independent educational meetings and symposia and grants or donations to healthcare organisations.⁵
2. The following are examples of sponsorships of independent educational events that must be reported:
   1. financial sponsorship of a third-party educational event;
   2. monetary contribution to support the conduct of grand rounds, clinic meetings or journal club meetings;
   3. purchase space for providing a trade display at an educational event (including if this is the only sponsorship of the event).
3. If a Company only directly or indirectly provides hospitality (food and beverages) for an educational meeting, this is not reportable. However, the hospitality must comply with the requirements of this Code.⁶
4. The following are examples of grants or donations that should be reported:
   1. disease awareness activities;
   2. production of educational materials.
5. Sponsorship of clinical trials or clinical research is not reportable.  Medicines Australia will make publicly available on its website the completed reports provided by each Company in accordance with the publishing dates specified in Section 14.4.
6. It is the responsibility of a Company to inform a third-party organisation that any sponsorship, grant or donation provided will be publicly disclosed, including the monetary value of the funding.

14.3 Support for Patient Organisations

1. It is reasonable for Companies to provide financial support and/or significant direct or indirect non-financial support to organisations that work to benefit Australian patients, and it is appropriate for these activities to be reported.
2. To encourage consistency in the content and format of these reports, Companies should include:
   1. the name of the patient organisation;
   2. a description of the nature of the support that is sufficiently complete to enable the average reader to form an understanding of the nature of the support; and
   3. the monetary value of financial support and of invoiced costs. For significant non-financial support that cannot be assigned a meaningful monetary value, the published information should describe clearly the non-monetary value that the organisation receives.
3. Medicines Australia will make publicly available on its website the completed reports in accordance with the publishing dates specified in Section 14.4.
4. It is the responsibility of a Company to inform a patient organisation that any sponsorship received by the patient organisation from the pharmaceutical Company, whether sponsorship of the organisation, a specific publication, website or activity, and including the monetary value of the sponsorship, will be publicly disclosed.

14.4 Reporting Schedule

Reporting dates and publication dates are fixed. Adjustments are only made where the  date falls on a weekend, in which case the date will be the Friday before.⁷

Report type	Period covered in report	Data submission to Medicines Australia	Date published
Payments and Transfers of Value to Healthcare Professionals	1 January to 30 June	Due to Disclosure Australia 31 October	10 November
	1 July – 31 December	Due to Disclosure Australia 30 April	10 May
Third-Party Meeting and Symposia Sponsorship and Grants and Donations to Healthcare Organisations	1 January to 30 June	Due to Medicines Australia 31 October	10 December
	1 July – 31 December	Due to Medicines Australia 30 April	10 June
Patient Organisation Support	1 January – 31 December	Due to Medicines Australia 30 April	30 June

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1. #63: Do we report payments made to HCP’s who don’t prescribe? ↩︎
2. #37: Philanthropy, Patient Organisation Support or Third-Party Sponsorship? ↩︎
3. #67: We have a fee-for-service arrangement with a Patient Organisation – is this reportable? ↩︎
4. #46: What is a Healthcare Professional? ↩︎
5. #6: Reporting virtual or hybrid third-party sponsorships ↩︎
6. #8: Reporting Third-Party Sponsorships ↩︎
7. #23: ToV to Healthcare Professionals: reporting late invoices ↩︎