Increasing consumerism and patient empowerment has driven a change in how the healthcare industry engages with patients to provide therapeutic solutions. The final installment of our three-part blog series explores how the rise of patient centricity is impacting the design of patient support programs (PSPs).

Adding value to patient support programs

Pharmaceutical and medical device companies develop PSPs to help patients gain maximum benefit from their prescribed treatment to improve patient health outcomes and promote the quality use of medicines. These programs play a key role in supporting patients, providing information about their condition, helping patients adhere to their medication taking and making better lifestyle choices. Traditional PSPs have often taken a “one-size fits all” approach to address patient non-adherence. 1

In this era of patient empowerment, however, there needs to be a different approach to designing PSPs that complements the role of healthcare professionals (HCPs) in patient care. Patients need to see the value for themselves in participating in a company’s program. Forward thinking healthcare companies understand the benefits of investing in holistic PSPs and will undertake patient research to gain insights into the support services they really need and provide platforms for patients to participate in their care. Figure 1 shows the structure of a “beyond the pill” holistic PSP whereby the program has clinical relevance beyond simple medication adherence. 1 For example, a valuable support service for patients beginning a biological therapy for example is to provide training on how to administer injections, which is also beneficial for HCPs since this added support can shorten the time to starting the patient on a new therapy. 2 Designing a holistic PSP can have multiple benefits for pharmaceutical companies including enhancing patient engagement, assisting quality use of medicines prescribing, providing evidence to payers of added value for patients and also retaining brand loyalty. 1,3

Figure 1. Holistic disease management approach to PSP

Adapted from “Creating Value Through Patient Support Programs”. 1

Patient support program key stakeholders

Understanding the patient journey

Each patient’s journey has various phases and companies should consider the needs of individual patients at these different times. 1 It is important to develop a deep understanding of the patient journey from the path to diagnosis, through to ongoing interactions with HCPs, treatment decisions for ongoing care, managing treatment side effects and re-evaluating the treatment plan. Developing knowledge of the patient journey in this way can reveal important opportunities to engage with patients and provide individualised support services at appropriate touch points when they are most receptive. Seeking out these opportunities is important because the way in which a patient and their support network respond to certain situations along the journey can impact their long-term health outcomes. 4

The effects of a patient’s illness on their life and the side effects of their treatment are often subjective and difficult to quantify such as when considering emotional, cognitive, psychological and social factors. Progressive PSPs ensure that patients are supported holistically in these ways in managing their illness and that the program itself is clinically relevant, i.e. has the ability to improve clinical outcomes even without the drug.5 This is particularly important for patients with a chronic illness who suffer relentless psychological, emotional and social effects of their disease and the challenge to remain adherent to their treatment regimen. Therapy adherence involves more than education or reminder services – it’s about the patient correlating an improvement in their overall well-being with medication taking and improved symptoms, which helps build patient loyalty to a brand. 2

CRC’s experienced Medical Affairs team can engage key stakeholders to inform development of PSPs that are not just about the medication taking but also encompass holistic disease management elements.


  1. Ockvirk A. 2016. Drug discovery and development magazine. Creating Value Through Patient Support Programs. Available at: https://www.dddmag.com/article/2016/03/creating-value-through-patient-support-programs
  2. Hensley E. Martini J. 2015. ZS Associates. Patient support programs that deliver results. Available at: https://www.zs.com/publications/articles/patient-support-programs-that-deliver-results.aspx
  3. Robinson R. 2014. PharmaVoice. Payers: Addressing the needs of payers. Available from: http://www.pharmavoice.com/article/payers/
  4. Ockvirk A. 2016. SKIM Group Presentation. Available at:https://www.slideshare.net/SKIMgroup/creating-value-through-patient-support-programs
  5. Butler A. 2015. LinkedIn Pulse. The five foundations of digital patient support programmes. Available at: https://www.linkedin.com/pulse/five-foundations-digital-patient-support-programmes-alex-butler




This second installment of our three-part series discusses how the Medical Affairs function is evolving to provide solutions that address the three areas of change discussed in last month’s blog, i.e. greater consumer empowerment, complex regulatory pathways and informing payers about real-world data.

Looking through ‘multiple lenses’ – the importance of stakeholder engagement

The most competitive pharmaceutical and medical device companies are those who integrate rapid technological developments, use of big-data and real-world evidence into their medical affairs functions (1). Medical affairs teams link scientific and clinical results to patient outcomes and communicate these insights strategically to stakeholders throughout the product lifecycle. Responding to changes in the healthcare industry requires innovative stakeholder engagement strategies driven by understanding the needs of patients, healthcare providers, regulators, payers and government.

One example of the importance of stakeholder engagement in an evolving medical affairs function is the rise of medical science liaisons (MSLs) in response to restrictions on the activities of sales representatives in promoting therapeutic products to healthcare professionals. MSLs are now more likely to gain access to medical key opinion leaders (KOLs) to hold peer-to-peer discussions and gain insights that can inform clinical strategies and contribute to building competitive advantage.

Patient engagement strategies

Harnessing patient insights has been shown to impact positively across multiple business areas in the pharmaceutical and medical device industries, yet patient-centricity remains somewhat an aspiration for some companies (2). The use of digital platforms such as apps to allow patients to communicate with healthcare professionals (HCPs) via video journal during clinical trials is increasingly popular. However, medical affairs teams who embrace this type of technology must be careful to cater first to the patient’s needs before the business needs. For example, apps can allow the HCP to respond to patient queries or schedule an earlier visit if they are concerned with their patient’s progress or side effects. These apps can then have the secondary goal of providing a tool for companies to gather insights that can later be disseminated to regulators, payers and other relevant stakeholders as part of the business strategy. Companies relying solely on data from patient-physician interactions are limiting their potential to gain insights about the patient journey and so need to realise the importance of innovation to improve on current standards of patient engagement (3).

Strategies to engage payers

The rising cost of healthcare has caused payers to seek cost-containment measures and new forms of evidence in showing the cost-effectiveness of therapies (4). Simultaneously, the pharmaceutical industry has become increasingly frustrated with the uncertainty around the funding of new therapies and so there is a growing need for companies to develop a new model of interaction with payers (4). One suggestion is for early and ongoing engagement with payers similar to the approach that pharmaceutical companies often take with KOL engagement (5). Some examples of strategies that can add value to payer engagement are the use of real-world data, incorporating support services that optimise the value of a therapy for patients, as well as tools to help payers assess the quality of those services and negotiating risk-sharing arrangements such as pay-for- performance (4, 5). By developing an evidence based relationship, payers and the pharmaceutical industry can collaborate to bring the most clinically effective and best value solutions to patients.

CRC’s experienced Medical Affairs team can develop effective engagement and market access strategies tailored to a client’s needs for building effective stakeholder relationships.


  1. Loic P, Schlegel C, Gordian M. 2017. Reinventing the role of medical affairs. Available at: http://www.bain.com/publications/articles/reinventing-the- role-of-medical-affairs.aspx
  2. Kinapse. 2015. Capitalising on Patient Insights. Available at: http://www.kinapse.com/media/1237/capitalising-on- patient-insights- kinapse-white-paper- february-2015.pdf
  3. Champagne D, Hung A, Leclerc O. 2015. McKinsey & Company How pharma can win in a digital world. Available at: http://www.mckinsey.com/industries/pharmaceuticals-and- medical-products/our-insights/how- pharma-can- win-in- a-digital- world
  4. Robinson R. 2014. PharmaVoice. Payers: Addressing the needs of payers. Available from: http://www.pharmavoice.com/article/payers/
  5. de Cent N. 2014. EyeforPharma. It’s time to go on the payer journey. Available at: http://social.eyeforpharma.com/evidence/its-time- go-payer- journey




Medical Affairs is undergoing an evolution of sorts. This is the first of a three-part series looking at three key areas where external landscape changes are impacting the Medical Affairs function.

1. Greater Consumer Empowerment

Unprecedented access to healthcare information has allowed patients to become more discerning about their health needs, which is influencing pharmaceutical and medical device companies to integrate patient centric strategies that impact across the organisation (1). Empowered consumers leverage knowledge to demand more sophisticated, convenient and personalised therapies (2).Traditionally, companies focused on satisfying the needs of regulators, payers and prescribers throughout the product life cycle, while patient insights were gathered indirectly via healthcare providers (3). However, patients have found their voice and the onus now is on industry to engage with them as key stakeholders and implement solutions that provide more considered support to patients.

Medical Affairs teams can respond to this by taking a ‘360-degree’ approach to engaging with patient communities in designing patient support programs (PSPs) that facilitate holistic disease management. This means the PSP does not simply focus on medication adherence but aims to demonstrate a deep understanding of how the disease and the therapy impact patient outcomes, which informs those services most meaningful to patients for improving their lives (3, 4). For example, PSPs developed for patients with diabetes may need to address the emotional, social and psychological impact of their condition, it’s monitoring and adhering to therapy, while a PSP for an oncology drug may require more focus on managing treatment side effects and how these impact patient lives.

2. Complex regulatory pathways

Innovative therapies, especially biological medicines, are being developed at an accelerated rate, which has created pressure on regulators to implement effective risk management solutions. In Australia, a series of reforms shown below have added to the burden of risk management activities for pharmaceutical and medical device companies (5).

Table reproduced from: https://www.tga.gov.au/sites/default/files/presentation-mmdr-consultation-strengthening-monitoring-of-medicines-in-australia-170426.pdf

These reforms include the introduction of the Black Triangle Scheme in Australia in 2017 (Figure 1), which has been in effect in the EU since 2013 (6). Black triangle notices will apply for a period of 5 years to biological medicines and therapies that contain a new active substance to indicate the medicine is subject to additional monitoring, as well as highlight the location of safety information along with details of how to report adverse reactions (5-7). These changes reflect the increasing concern of regulators and consumers about the long-term safety risk of some new medications,specifically biologicals that can cause increased risk of adverse events (7). These reforms can only benefit patient outcomes via the increased safety vigilance and risk management, however companies may be challenged by the increased workload and resource implications.

Figure 1. Example of new product labelling under the Black Triangle Scheme.

3. Informing payers about real world data

Healthcare systems globally are evolving from high cost fee-for-service based models towards value-based systems linking payment to performance and, as discussed previously, Australia has been slow to implement these changes (8). There is increasing pressure on pharmaceutical and medical device companies to demonstrate not just clinical effectiveness but the value for money their products provide. This is no longer achieved solely through traditional evidence based medicine in the form of clinical studies to prove the safety and efficacy of a therapy. In fact, companies are now facing unpredictable reimbursement decisions and are challenged to implement strategies to prove long-term, real-world clinical and cost-effectiveness outcomes in securing funding for new therapies (9, 10). Industry as a whole could therefore benefit from coming together as ‘change agents’to face this challenge by working with payers to establish the appropriate mechanism in progressing the collection and use of real world evidence to support therapy funding.

CRC’s mission is to increase our clients’ competitive edge by implementing Medical Affairs solutions to maximize commercial opportunities. Our dedicated Medical Affairs experts are well equipped to find strategic approaches for the current challenges facing industry and implement them with our clients.


  1. Taylor K, Steedman M, Sanghera A. 2017. Deloitte. Pharma and the connected patient – How digital technology is enabling patient centricity. Available at: https://www2.deloitte.com/content/dam/Deloitte/uk/Documents/life-sciences-health-care/deloitte-uk-pharma-and-the-connected-patient.pdf
  2. Figgis P, Walters C. The Empowered Consumer. Available at: http://www.pwc.com/gx/en/industries/healthcare/emerging-trends-pwc-healthcare/new-entrants-healthcare-provision.html
  3. Gosling H. 2016. Patient-centricity: Ghost in the machine. Available at: http://www.pharmatimes.com/magazine/2016/may_2016/patient-centricity_ghost_in_the_machine
  4. Ocvirk A. 2016. Creating value through patient support programs. Available at: https://www.dddmag.com/article/2016/03/creating-value-through-patient-support-programs
  5. Cook J. 2017. Therapeutic Goods Administration. Strengthening monitoring of medicines in Australia. Available at: https://www.tga.gov.au/sites/default/files/presentation-mmdr-consultation-strengthening-monitoring-of-medicines-in-australia-170426.pdf
  6. European Medicines Agency. 2013. Medicines under additional monitoring. Available at: http://www.ema.europa.eu/ema/index.jsp?curl=pages/special_topics/document_listing/document_listing_000365.jsp
  7. Scott S, Griffiths M. 2017. ABC News. Therapeutic Goods Administration considering new ‘black triangle’ warnings to make medicine safer. Available at: http://www.abc.net.au/news/2017-03-20/new-black-triangle-warnings-aim-to-make-medicine-safer/8369530
  8. O’Reilly N. 2017. From evidence based medicines to value based healthcare – is Australia ready? Available at: https://crcaustralia.com/media-releases/from-evidence-based-medicine-to-value-based-healthcare-is-australia-ready/
  9. Sackman J, Kuchenreuther M. 2015. BioPharm International. Market Access Outlook for Australia. Available at: http://www.biopharminternational.com/market-access-outlook-australia?__hstc=40333757.a7b8394010b2114973f462b41afaf8dc.1494816515259.1500334787588.1500422925924.13&__hssc=40333757.1.1500422925924&__hsfp=2974958270
  10. Loic P, Schlegel C, Gordian M. 2017. Reinventing the role of medical affairs. Available at: http://www.bain.com/publications/articles/reinventing-the-role-of-medical-affairs.aspx





National Diabetes Week from July 9th – 15th aims to raise awareness about diabetes, its management and prevention (1). Diabetes presents a huge disease burden with the prevalence of diabetes worldwide estimated at 422 million people, including 1.7 million Australians among whom 500,000 are undiagnosed (2, 3). Each day 280 Australians are diagnosed, which is one person every five minutes (3). The healthcare costs of diabetes in Australia are around $1.7 billion per year, yet when indirect costs such as lost productivity, work absenteeism, and early retirement are also considered, the total cost burden may be as high as $14.6 billion (3, 4).

Insulin is the hormone that regulates blood glucose levels in the body. Type 1 diabetes is an autoimmune disease whereby a person’s immune system destroys the insulin producing cells of the pancreas. In type 2 diabetes, which represents the majority of the disease and cost burden, the body becomes resistant to the normal effects of insulin and/or cannot produce enough insulin. Type 2 diabetes is generally lifestyle related and often associated with obesity/overweight and physical inactivity, yet it is preventable. Increasing the disease burden are a further 2 million Australians with pre-diabetes who are at risk of developing type 2 diabetes (5).

What is the impact of poor glucose control?

Poor control of glucose levels risks the development of micro- and macro-vascular damage, which can result in heart disease, stroke, blindness, kidney failure and lower limb amputation (3, 6). The extent of the burden of these complications is shown in Figure 1 (3). Of particular concern is that only around half of Australians with diabetes achieve the general HbA1c (glycated haemoglobin) glycaemic target of 7% or less (7). HbA1c is the average blood glucose level over 3 months, however it does not provide insights on the extreme high and low glucose levels that people with diabetes may experience on a daily basis. Therefore, even individuals with an acceptable HbA1c result may be at risk of developing diabetes related complications if there is considerable out of range variability in their daily glucose levels (8).

Figure 1. Poorly controlled diabetes leads to complications

It’s not only about glucose levels

Diabetes is a complex chronic and progressive condition affecting people not only physically, but often also their cognitive, psychological, emotional and social well-being (9-11). Poorly controlled glucose levels can negatively impact cognitive function and daily activities (9), while the burden of managing diabetes may lead to emotional distress for affected individuals and their family/carers (11). People with diabetes are also twice as likely to suffer from depression compared to those without diabetes (10). Remaining motivated to manage their diabetes without ever having a break becomes a relentless challenge that can leave affected people frustrated and overwhelmed (10, 11). This may result in “diabetes burnout”, which manifests as self-destructive behaviours such as eating unhealthy food and administering estimated insulin doses without prior glucose testing in an attempt to ‘free’ themselves from the confines of their condition (12).

How do available self-glucose monitoring methods measure up?

A key aim of glucose monitoring is to keep glucose levels within a specified target range and so avoid the extreme highs and lows that can lead to acute and long-term complications (7, 8). Glucose monitoring also shows those with diabetes the effects of food intake, exercise, medications and other factors (e.g. illness) on their glucose levels. However, available self-monitoring methods may not be fulfilling their needs. Indeed, one may argue that these methods, which are invasive, serve as a constant reminder to people about their diabetes.

The most widely used glucose monitoring method is self-monitoring blood glucose (SMBG) or “finger stick” testing. However, many individuals are not performing SMBG as recommended, typically because it is invasive, painful, inconvenient, time consuming and tends to undermine their daily activities (12, 13). Indeed, a comprehensive review identified that people with type 2 diabetes not prescribed insulin fail to regularly monitor their blood glucose levels (15). Alternative systems such as flash glucose monitoring (FGM) and continuous glucose monitoring (CGM), while providing individuals with a more complete picture of their glucose levels, are still invasive. These technologies are also not readily accessible to many people with diabetes due to their lack of suitability (e.g. requires technical competence) and high cost, while calibration with finger sticks is still needed.

Is non-invasive glucose monitoring the answer?

Maintaining good control of glucose levels is essential for people with diabetes to stay healthy and prevent or reduce the risk of complications. Moreover, these individuals want to be in control of their diabetes rather than the condition controlling them. This presents a real opportunity for a glucose self-monitoring system that is non-invasive, accurate, painless, convenient and discrete with the ability to transmit data to their family/carers and healthcare providers (16). Such a system also has the potential to considerably improve adherence to self-monitoring which, in turn, would help to reduce the diabetes burden and associated healthcare system costs (16).

To this end, a key emerging technology is saliva based glucose detection, which presents an attractive and potentially more accurate, sensitive and low-cost alternative to available methods for measuring glucose levels. This is because saliva based technology offers non-invasive, painless and convenient sample collection with the ability to detect glucose concentrations 100 times lower than identified in blood (17,18). Glucose detection in saliva is a simple, discreet process involving a small disposable test strip impregnated with glucose oxidase, which is placed in the mouth. The glucose oxidase reacts with the glucose in saliva to ultimately produce an electrochemical signal that is subsequently processed by a handheld reader or smart device to produce a glucose level reading.

To have a non-invasive, painless, convenient and discreet method for monitoring glucose levels, ideally with data connectivity to inform family members, carers and healthcare providers, would be the ‘Holy Grail’ in diabetes management and prevention.

Fortunately, an innovative, first in class, saliva-based technology for monitoring glucose levels, which has all these attributes and is likely to be low cost, is on the horizon. Called the glucose biosensor system, it is expected this technology will go a long way in helping address the growing diabetes burden across the globe. For further details see Glucose Biosensor.

Figure 2. Image of salivary glucose biosensor

Can more be done beyond available glucose monitoring methods to manage and even prevent diabetes? To help affected individuals gain control over their diabetes? Absolutely.

Diabetes is a therapeutic area about which CRC is passionate. Based on our team’s solid medical affairs and market access expertise in this and many other therapeutic areas, we welcome the opportunity to plan and implement a wide range of initiatives in contributing to the commercial success of our pharma, biotech, device and other healthcare industry clients.


  1. Diabetes Australia. 2017. National Diabetes Week. Available at: https://www.diabetesaustralia.com.au/itsabouttime. [Accessed 12 July 2017].
  2. World Health Organization. 2016. Global Report on Diabetes.
  3. Diabetes Australia. 2017. Diabetes in Australia. Available at: https://www.diabetesaustralia.com.au/diabetes-in-australia. [Accessed 12 July 2017].
  4. Australian Government Department of Health. 2016. Australian National Diabetes Strategy 2016-2020.
  5. Diabetes Australia. 2017. Pre-diabetes. Available at: https://www.diabetesaustralia.com.au/pre-diabetes. [Accessed 12 July 2017].
  6. Diabetes UK. 2016. Diabetes UK Key facts and stats.
  7. Shaw J, Tanamas S. Diabetes: the silent pandemic and its impact on Australia. Diabetes Aust. 2012. 1–52.
  8. Sun S, Kim J H. Glycemic Variability: How do we measure it and why is it important? Diabetes Metab J. 2015;39: 273-282.
  9. Kodl CT, Seaquist ER. Cognitive dysfunction and diabetes mellitus. Endocr Rev. 2008;29(4):494–511.
  10. Debono M, Cachia E. The impact of diabetes on psychological well-being and quality of life. The role of patient education. Psychol Health Med. 2007;12(5):545–55.
  11. SANE Australia. The SANE Guide to Good Mental Health for people affected by diabetes. 2008.
  12. Diabetes UK. Diabetes Burnout. 2017. Available from: http://www.diabetes.co.uk/emotions/diabetes-burnout.html [Accessed 12 July 2017].
  13. Diabetes Australia. Fact sheet “Your SAY Glucose Monitoring” Study.
  14. Moström P, Ahlén E, Imberg H, Hansson P-O, Lind M. Adherence of self-monitoring of blood glucose in persons with type 1 diabetes in Sweden. BMJ Open Diabetes Res Care. 2017;5(1).
  15. Post-Market Review of Products Used in the Management of Diabetes Part 1: Blood Glucose Test Strips. 2013;1–78.
  16. NHS National Institute for Health Research. Horizon Scanning Research & Intelligence Centre. New and emerging non-invasive glucose monitoring technologies. 2016.
  17. The Australian. New saliva test for blood sugar could help diabetics. 2015. Available from: http://www.theaustralian.com.au/business/technology/new-saliva-test-for-blood-sugar-could-help-diabetics/news-story/8c7501a2858de7cb44c734538b7d9077 [Accessed 12 July 2017].
  18. The iQ Group Global – Glucose Biosensor. 2017. Available from: https://youtu.be/ifLqii2efao [Accessed 12 July 2017].




In an ideal world, healthcare professional (HCP) education about pharmaceutical and medical device therapies is always distinguishable from promotion. Yet the reality is that medical education and promotion can sometimes cross paths such that their distinction becomes blurred. Indeed, one could argue that medical education conducted by pharmaceutical and device companies is a form of promotion as the reality is that there is ultimately a product to sell. On the other hand, since the pharmaceutical/medical device company researched and/or developed the product, it can also be argued that the company is amongst those best placed to educate HCPs about that product.

Medical education and promotion are quite different activities:

  • Medical education is an activity providing accurate, balanced and scientifically valid information about a medical condition or therapy without any specific promotional claims.
  • Promotion of a therapy includes any representation that is persuasive and conveys the positive attributes of a product to encourage its prescribing, use, sale, purchase or supply.

However, when does the line between these two distinct activities become blurred? The following three cases, adjudicated by the Medicines Australia Code of Conduct Committee (“Committee”), help to shed some light.

Case 1. Selective data as medical education

Scientific or technical information provided to HCPs should be fair, accurate and balanced, particularly comparative information between therapies, to support clinical decision-making. Yet what if a pharmaceutical company’s Medical Liaison team was to distribute an email to HCPs containing selective excerpts of efficacy and safety data from a regulatory agency assessment report to favourably compare its therapy with a competitor product? This was the case where the selective extraction of data in an email was consequently considered by the Committee to be unfair, unbalanced and misleading to HCPs.(1) Being extracted data, it was without relevant context and omitted key report information about the competitor therapy, The selective email information thus did not accurately reflect the equivalent report content and would likely have the effect of discouraging use of the competitor therapy, while encouraging use of the company’s product. Although the full report was provided in the email, the Committee concluded the email content was promotional information and not medical education as it provided selective data to discredit the competitor therapy.(1)

Case 2. Off-label information as medical education

Companies are responsible for ensuring therapy content at medical educational meetings aligns with the approved Product Information and to brief HCP speakers accordingly when presenting at these events. However, at one meeting (one of a series of educational meetings sponsored by a pharmaceutical company) the international HCP speaker presented study data on the long-term use of a drug for up to 12 years, although its approved treatment duration was 12 weeks.(2) Moreover, the data presented was for a different compound of the drug moiety to that approved in Australia, which was indicated for a maximum of 12 weeks’ use. The Committee concluded the educational content focused on a product not available in Australia, although containing the same drug moiety, and would encourage off-label prescribing for long term use which, in turn, had potential safety implications for patients. In this case, educating on the long-term use of an unapproved compound of the same drug moiety was tantamount to off-label promotion of the long-term use and associated safety of the approved product in Australia.(2)

Case 3. Manufacturing tour as medical education

The primary objective of HCP attendance at company sponsored medical education events is to enhance medical knowledge and the quality use of medicines. Companies must be able to justify the event’s educational content and its relevance to HCP attendees’ area of expertise. However, would an overseas manufacturing facility tour organised (and sponsored) by a pharmaceutical or medical device company qualify as necessary HCP education? On the surface, one of two extremes could be argued – either it is education overkill or an example of promotion disguised as medical education.

Yet it was neither of these extremes in a case adjudicated by both the Medicines Australia Code of Conduct Committee and Appeals Committee where a pharmaceutical company had organised for a group of HCPs to visit its biotechnology manufacturing facility following their attendance at a nearby third party scientific meeting.(2) The tour aimed to provide HCPs experiential understanding of the manufacturing process – its complexities, challenges and quality standards – for a specific biological therapy by seeing it first-hand. This would help to build their confidence of the process, as well as knowledge of potential patient reactions to the therapy’s complex protein molecules. The HCPs would also benefit from interacting with the R&D and manufacturing process personnel, which in turn could benefit patients. The Appeals Committee accepted the appropriateness and relevance of the tour for these reasons and so overturned the Code of Conduct Committee’s view that the purpose was to promote the company’s biological product, encouraging HCPs to continue prescribing and recommending. Of relevance is that there was no biological substitute for the company’s product, while other companies had held similar manufacturing plant tours for HCPs in educating on the complexities of biological therapies.(2)

Erasing the blur

The above mentioned cases show that the line between medical education and promotion is not always clear. Rigorous scrutiny in the planning of medical educational activities and content – ideally via a quality control process involving various stakeholders who can provide multiple perspectives – is therefore important to minimise the risk, intentional or unintentional, that the education becomes, or is perceived to be, promotion.

These cases also illustrate the importance of context. In Case 1, the selective use of data emailed to HCPs, which was non-contextualised, showed how incomplete information can easily morph from education to promotion, whereby the data becomes distorted, biasing one therapy over another. In Case 2, where an educational meeting focused on the long-term treatment duration of an unapproved compound with the same drug moiety as the approved product indicated for short-term use, HCPs will likely be encouraged to prescribe the latter for long-term use. Whether this effect was inadvertent or not, the meeting’s educational value was consequently outweighed by the promotional goal. Case 3 shows that even when an educational activity is consistent with industry standards and benchmarks and there is a broader relevant context to justify it – in this example the need to provide HCPs experiential learning about a complex biologicals manufacturing process that could not realistically be provided another way – the (mis)perception of promotion disguised as education may still arise.

Medical education and promotion are both key activities conducted by pharmaceutical and medical device companies. Our dedicated Medical Affairs team at CRC is well equipped to help plan and implement a wide range of impactful, yet compliant educational and promotional review activities for healthcare industry clients, ensuring the line between medical education and promotion is clear.


  1. Medicines Australia. Code of Conduct Annual Report 2013-2014.
  2. Medicines Australia. Code of Conduct Annual Report 2014-2015.

CRC provides Medical Affairs solutions to the Pharmaceutical industry throughout the Drug Development Life Cycle. Our objective is to maximise the value of therapeutic compounds from pre-launch through to commercialisation and beyond.

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