Q&A Regarding Our Relationship with Healthcare Professionals
Healthcare professionals play a vital role
in helping Cephalon develop and bring medicines to market that address patients’
unmet medical needs. It is our aim to shed light on the true nature and benefit
of these relationships and to reinforce our company’s commitment to conduct
our business responsibly and with integrity.
Therefore, to further better understanding of our relationships with healthcare
professionals, we have included answers to likely questions you may have below.
- Why has Cephalon agreed to publish information on its website
regarding the financial relationships with healthcare professionals who advise or
consult with Cephalon?
- Are fees paid to healthcare professionals by pharmaceutical companies
like Cephalon contributing to the rising cost of healthcare?
- How does Cephalon select the healthcare professionals who perform
services on its behalf?
- What types of expenditures to healthcare professionals does Cephalon
- Why do Cephalon and other pharmaceutical companies provide meals
to healthcare professionals?
- Does Cephalon permit “gifts” to be given to healthcare
- Is there any relationship between the services healthcare professionals
provide Cephalon and their prescribing activity related to Cephalon products.
- Does Cephalon cap the annual amount of fees that may be paid
to an individual healthcare professional?
- How does Cephalon determine how much to pay healthcare professionals
for their services?
- How often will Cephalon update information posted to its website
regarding payments made to healthcare professionals?
- Should I be concerned if my healthcare professional is listed
on the Cephalon website?
- What is the difference between the Expenditures to Healthcare
Professionals database and the 2010/2009 Fees for Services databases?
1. Why has Cephalon agreed to publish information on its website regarding the
financial relationships with healthcare professionals who advise or consult with
Cephalon supports transparency in its financial relationships with healthcare professionals.
We believe it is important for the public to understand that our partnerships with
healthcare professionals allow us to develop and bring new medicines to market,
address the needs of patients, and assure the safe and appropriate use of our medications.
On September 28, 2008, Cephalon entered into a Corporate
Integrity Agreement (CIA) with the Office of the Inspector General of the
U.S. Department of Health and Human Services. As part of this agreement, Cephalon
agreed to post on its Web site all payments to, and spending on, prescribers of
our medications. Cephalon's CIA disclosure requirements are similar to those currently
in place in several states, as well as those contained in the Physician Payments
Sunshine Act that impact the entire pharmaceutical industry.
2. Are fees paid to healthcare professionals by pharmaceutical companies like
Cephalon contributing to the rising cost of healthcare?
No. Government agencies and independent experts alike have concluded that there
is no direct relationship between pharmaceutical marketing, including those services
for which pharmaceuticals pay healthcare professionals, and drug prices or overall
According to the Centers for Medicare & Medicaid Services, for more than a decade,
prescription medicines have accounted for only 10 cents of every healthcare dollar
spent. These medicines have increased survival rates for cancer and other diseases
and have improved the management of chronic medical conditions such as diabetes
and high blood pressure.
3. How does Cephalon select the healthcare professionals who perform services
on its behalf?
Cephalon invites healthcare professionals
to provide services on our behalf primarily based on their expertise within the
therapeutic areas related to our products. We do not grant preference to healthcare
professionals based on prescribing activity, nor do we place any expectations on
future use of our products.
Once a healthcare professional has been selected to perform services on behalf of
Cephalon, we check for federal debarments, and confirm state medical licensure and
Drug Enforcement Agency (DEA) licensure, when applicable.
4. What types of expenditures to healthcare professionals does Cephalon
Beginning in January 2010, Cephalon disclosed total 2009 fees for services paid
to each individual healthcare professional contracted to conduct
Company-sponsored peer-to-peer educational speaker programs or provide
advisory or consulting services. Throughout 2010 via quarterly reports,
Cephalon disclosed these same types of payments that occurred during 2010.
In March 2011, Cephalon began disclosing not only payments related to speaker programs
and advisory or consulting services the occurred in 2010, but also
travel-related expenses associated with services provided and payments made
to healthcare professionals for conducting clinical research. Where applicable and
identifiable, payments directed to an institution, hospital, or organization for
services performed by an individual healthcare professional are disclosed. In addition,
Cephalon is disclosing educational meals and educational items that are greater
than or equal to $10, and/or where the aggregate amount paid to an individual healthcare
professional is greater than $100 in a calendar year.
5. Why do Cephalon and other pharmaceutical companies provide meals to healthcare
In light of the fact that healthcare professionals
often have hectic schedules that require them to balance patient care and other
responsibilities, our representatives present scientific or educational information
during meal times. On such occasions, we permit our representatives to provide a
modest meal to physicians and staff who attend the presentations, as long as it
is deemed conducive to the exchange of information, and does not present any entertainment
or recreational benefits to healthcare professionals.
Meals are also provided in conjunction with
Company-sponsored peer-to-peer educational speaker programs in which a contracted
healthcare professional provides medical or scientific information to a group of
other healthcare professionals on behalf of Cephalon.
Cephalon strictly adheres to the guidelines developed by the Pharmaceutical Research
and Manufacturers of America (PhRMA) that call for ethical interactions with healthcare
professionals, also known as the PhRMA Code.
All meals provided by Cephalon to healthcare professionals are in accordance with
the PhRMA Code.
6. Does Cephalon permit “gifts” to be given to
Yes, but only if those gifts are educational in nature and enhance patient care
or advance health education. Therefore, any items provided in the course of these
interactions must be designed primarily for the education of patients or
healthcare professionals, such as an anatomical model for use in an examination
room. Such educational items are deemed
appropriate if they are not of substantial financial value and do not offer value
to healthcare professionals outside their professional duties.
In recognition of the possibility that some items may foster misperceptions and
distract from the educational intent of interactions with healthcare professionals,
Cephalon no longer provides non-educational items, such as pens, notepads or other
7. Is there any relationship between the services healthcare professionals provide
Cephalon and their prescribing activity related to Cephalon products?
No. Contracting with healthcare professionals
to provide advisory and consulting services to Cephalon is neither intended to influence
their prescribing activity in any way nor has it been found to be the most influential
factor in prescribing decisions. Based on the latest research, the most common factors
affecting prescribing decisions include, the patient’s unique situation, the
healthcare professionals’ knowledge, data from a peer reviewed publication
or a peer, clinical practice guidelines, knowledge obtained through
continuing medical education, patient’s insurance coverage and out
of pocket costs.
8. Does Cephalon cap the annual amount of fees that may be paid to an individual
In accordance with the PhRMA Code, Cephalon caps the total amount of fees paid to
individual healthcare professionals in connection with conducting company-sponsored
peer-to-peer educational speaker programs.
9. How does Cephalon determine how much to pay healthcare professionals for
Cephalon has established Fair Market Value
guidelines to assure that compensation provided to
healthcare professionals is appropriate for the services they provide. These
guidelines are used to determine the compensation level of each healthcare professional
based upon his or her individual qualifications. Compensation and the scope of services
to be provided are clearly defined in a written agreement prior to the provision
Considerations that are factored into the calculation of a healthcare professional’s
fair market value for a particular service provided to Cephalon include:
- Specialty and area of expertise. Based on market conditions within the healthcare
industry, oncologists are compensated at a higher rate for services they perform
than are pediatricians.
- The healthcare professional’s level of expertise. A recognized leader within
a medical specialty with deep clinical expertise would garner a higher rate of compensation
than a specialist who did not possess a comparable level of achievement or experience.
- The scope of the work required. Chairing an advisory board would require a greater
degree of preparation and involvement than merely participating on the board, which
would be reflected in the compensation of the healthcare professionals who provide
the respective services.
Other factors may be considered depending on the type of activity in which a healthcare
professional participates and his or her credentials related to carrying out that
10. How often will Cephalon update information posted to its website regarding
payments made to healthcare professionals?
Cephalon will update information related to payments made to
healthcare professionals on a quarterly basis.
11. Should I be concerned if my healthcare professional is listed on Cephalon’s
No. If your personal physician is listed on our Web site it is because he or she
possesses expertise within the therapeutic areas related to Cephalon products and
has an interest in educating other healthcare professionals
about the appropriate and safe use of our products.
12. What is the difference between the type of information included in the Expenditures
to Healthcare Professionals database and the 2010/2009 Fees for Services databases?
The Expenditures to Healthcare Professionals database contains a list of healthcare
professionals with whom Cephalon has contracted to conduct
Company-sponsored peer-to-peer educational speaker programs, provide
advisory or consulting services, or conduct
clinical research. The database also contains other types of spending
and items of value, including travel-related
expenses, educational meals, and
The 2010/2009 Fees for Services databases contain lists of healthcare professionals
with whom Cephalon has contracted to conduct Company-sponsored peer-to-peer educational
speaker programs or provide advisory or consulting services.