Q. What safeguards are in place for compliance?
A. All donations are made directly to charities. No funds are transmitted to healthcare professionals. Donations cannot be restricted or earmarked. Doctors must certify that neither they, nor a family member, holds a position on the board of the charity, is employed by the charity, or has other financial relationships. The charitable donations would not be determined in any manner that relates to a healthcare professional’s prescribing choices, thereby precluding any potential link between the opportunity and a healthcare referral. The pharma client would not be apprised of any individual healthcare professional’s charity of choice, minimizing any opportunity for clients to use that information to identify charities favored by a particular doctor. Moreover, the surveys and offer would not be provided as part of any electronic prescribing transaction, thus eliminating any explicit link between the opportunity and a prescription or order of a product. Information must be FDA compliant and must not be used for any off-label marketing. Finally, there are dollar limits on the donation per completed survey (which are uniform for all respondents of a given survey), and on the annual aggregate donation to anyone charity on behalf of any one doctor.