According to the rules of the FSA Transparency Code, an initial disclosure in the year 2016 will contain the data from the year 2015. Given the size and complexity of the task, a targeted implementation is to be organised in 2014:
- The companies require sufficient time to adapt their internal systems, or in some cases, develop them completely from the ground up. The systems must track the payment flows from all departments, across all sectors and borders, in order to guarantee the correctness and completeness of the relevant data. Because it involves a European process, it must be ensured that the data exchange between all national subsidiaries and affiliates occurs smoothly. The disclosure of individual amounts involves sensitive data: Once amounts are disclosed on the Internet, they are out there in the world, therefore they must be 100% correct - it's a big challenge.
And there are lots of legal issues to consider: German data protection law is very strict. It mandates that entities involved must provide express consent if personal details are to be made public. That is why we must naturally involve all the relevant groups in the discussion, especially the physicians, and win them over for the project. In doing so, we are counting on the support of the German Medical Association, so that our joint efforts will lead this project to success.
Full transparency in the cooperation of pharma companies and physicians also strengthens the legitimate expectations of patients: They should receive information about the existence and scope of cooperation between their treating physicians and pharmaceutical companies.
The success of this initiative will crucially depend on the extent to which the other stakeholders in the healthcare system also agree to greater transparency. Thus the cooperation of physicians in disclosure of individual data is essential according to existing data protection law. Therefore, it is a matter of vital importance to the German Association of Research-based Pharmaceutical Companies (vfa) to enlist support for this project among physicians and also other stakeholders affected by it. That is why the vfa and the FSA have entered into a dialogue with physicians on this issue.