Navigating the relationship between science/medicine and commercial interests can be tricky. For most pharmaceutical companies, this boils down to the relationship between the company’s Medical Science Liaisons (MSLs) and commercial sales and marketing teams. Although they occupy vastly different roles within the company, each group is critically important to the company’s success. However, because of the highly influential nature of these two groups, companies must carefully control and monitor their interactions. Otherwise, unregulated scientific and commercial interactions could quickly morph into non-compliant behavior.
Science Vs. Sales: Defining the Difference
Both MSLs and commercial teams interact regularly with Healthcare Professionals (HCPs). However, as each team has very different roles and compliance requirements, the ways they are allowed to interact with HCPs vary dramatically. To better understand the relationship between MSLs, commercial teams, and HCPs, it’s important to define the specific role each group plays within a company.
Healthcare Professionals are anyone who provides or could provide healthcare services or items to patients. This includes the use, purchase, lease, prescription, or recommendation of healthcare products. Because HCP roles are so broad and influential, guidelines such as the PhRMA Code exist to help companies navigate appropriate and ethical interactions.
The Commercial Team
Pharmaceutical commercial teams (sales reps and marketers) handle the sale and promotion of drug products. Because all promotional activity must be based on the FDA-approved product indications, discussing off-label drug uses with HCPs is illegal. All on-label promotions must be factual and not misleading to consumers. With this in mind, sales reps and marketers may only take part in substantially commercial-related discussions.
Medical Science Liaisons communicate vital information to internal functions and clinical investigators. Part of their responsibilities include engaging HCPs in scientific exchange, bringing together top thought leaders to foster innovation, scientific development, and address unmet needs within the healthcare community. MSLs are allowed to discuss off-label uses with HCPs, so long as the information provided is truthful, balanced, and free of influence from commercial teams. These interactions must be documented and may only take place as part of a substantially science-based discussion.
Why Controlled Scientific and Commercial Interactions Are So Important
Ensuring ethical interactions with HCPs is a delicate balancing act. On one hand, a commercial team must promote products in order to make sales. Conversely, your company’s scientific/clinical team has a duty to report product information that’s completely free of commercial influence. When these two areas converge, the result could lead to medical decisions that are biased by commercial interest.
While it may seem safer and easier to completely segregate scientific and commercial teams, doing so would be counterproductive. In fact, there are many circumstances where joint interactions between scientific and commercial teams are unavoidable and even beneficial. HCP speaker programs, HCP introductions, CRM requests, and sales training are common areas of overlap where both MSLs and sales/marketing may be present. Many companies encourage conversation with appropriate guardrails between the two groups, as it makes interactions with HCPs more efficient. As long as there are appropriate boundaries in place, scientific and commercial teams are more than capable of having productive, compliant interactions.
How Training Can Help
So what’s a healthcare company to do in the face of so much joint scientific and commercial interactions compliance risk? Fortunately, learning solutions can greatly reduce risk for both your scientific and commercial teams. Here are a few strategies to get the most out of your employee training program:
Clearly Explain the “Dos and Don’ts”
Explaining the “dos and don’ts” is the meat of your medical and commercial rules of engagement training. Scientific and commercial employees need to know exactly what interactions are acceptable, and which are grounds for a compliance violation. These explanations should be crystal clear—preferably with short sentences or bulleted lists free of jargon and legalese. An ideal list of “dos and don’ts” is general enough to apply to a variety of interactions, but specific enough that there’s little to no room for misinterpretation. Including periodic knowledge checks or a final assessment is a useful way to measure how well employees understand acceptable versus unacceptable interactions.
Tailor Training to Each Team
Just because scientific and commercial teams both need training on appropriate interactions doesn’t mean your company should train them in the exact same way. Each team has their own specific role and responsibilities—there’s no point in making an MSL sit through training on how commercial teams should engage with HCPs or vice versa. For the most effective use of time, consider breaking up the training and assigning it only to relevant team members. That way, employees can increase their focus and gain more in-depth knowledge than they ever could from a generalized approach.
Utilize Scenario-Based Learning
Scenario-based learning tests if employees can actually apply what they learned to real-life situations. That way, employees can practice and make mistakes in a safe environment without any real consequences. For a richer experience, try using situations your company has already encountered in the past and may encounter again. Examples could address how to respond to an HCP’s request for off-label information, or how to properly document an interaction with an HCP.
Provide Follow-up Resources and Contact Information
Over time, employees will inevitably start to forget what you’ve taught them. In order to keep information fresh, follow-up with additional training (usually in the form of microlearning) or informational resources. One effective strategy is to condense the training content into an infographic or interactive PDF that employees can easily access when needed. If nothing else, make sure every employee knows how to get in touch with your company’s compliance team if they have any questions.
Launching Your Scientific and Commercial Interactions Compliance Training
The relationship between your company’s scientific and commercial teams will always be fraught with compliance risk. The question is, how much? With comprehensive training, both groups will be better prepared to interact with one another and HCPs while remaining compliant. For companies that don’t have the time or expertise to develop training, consider enlisting a learning consultant to help map out and develop a program. For best results, consider a custom training solution. While a bit more labor-intensive, custom training can be built around your needs and budget while offering the greatest long-term payoff.
Don’t wait to kickstart your company’s scientific and commercial interactions training. Get in touch with our team of compliance experts today.