To combat further erosion of their business, IMS has teamed up with the AMA to write a Pharmaceutical Executive Magazine article extolling the virtues of the AMA's Prescribing Data Restriction Program (PDRP). You can download the article ("More Than a Game of Keep-Away") here.
The article states flatly:
"If the industry cannot police itself effectively, state legislatures are likely to pass laws banning reps' access to prescriber data. Legislation has been introduced in several states this year, but the prospect of the PDRP program has stalled most of the bills. Only effective self-regulation can keep such laws off the books."I have no beef with that goal. I do believe, however, that the authors (Hunkler is Director of Professional Relations at IMS and Musacchio is CIO at AMA) are not presenting the best arguments to support their case. In fact, some of their arguments may be counterproductive and at least one is laughable.
As I have said elsewhere, physician prescribing data can be useful to target specific promotions to physicians and offer them more relevant information and thereby improve pharma-physician relationships. Considering the poor state of this relationship, I believe this argument is a sufficient defense of the use of Rx data for marketing (assuming, however, that the data is actually used that way).
The authors of the PE paper, however, go much further. I think they go too far, in fact. They argue, for example, that use of Rx data by pharma actually LOWERS healthcare costs!
"Opponents of prescribing data have argued, erroneously, that using prescribing data to support pharmaceutical sales and marketing somehow burdens the healthcare system with additional cost. The facts suggest just the opposite. Prescribing data allow pharmaceutical promotion to be relevant and specific, making the whole process more cost-effective (and sparing physicians from being bombarded with extraneous promotional materials and sales calls)."I don't know who has said that use of prescribing data by pharma for marketing purposes burdens the healthcare system. Yes, there are those people who say that pharmaceutical marketing, in general, increases drug costs, but that's a different issue. Nevertheless, by using this argument, the authors admit that "bombarding" physicians with "extraneous promotional materials and sales calls" adds cost to the healthcare system!
To accept the authors' argument, you have to believe that high-prescribing physicians are visited LESS by pharma reps and this just isn't generally true. Much of pharmaceutical marketing is aimed at "high decile" physicians. Of course, it may not be marketing originating from the brand that the physician prescribes frequently. Generally, if a physician is a high prescriber of drug X, then competitor drug Y's sales reps will set upon him/her like flies on dung. Also, I'm not so sure that drug X salespeople ignore these high prescribers.
Another argument in favor of pharma use of Rx data the authors of the PE paper make is that it allows pharma companies to more quickly notify physicians of product recalls.
"[Physician prescribing data can] Help prioritize the release of public safety news alerts Based on physician prescribing details, companies can identify which physicians need to be contacted first in the event of a newly identified side effect or a product recall."PhRMA makes a similar argument:
"Foreclosing all access to prescribing data could also hamper manufacturers' ability to alert physicians of important new information about medicines in a timely fashion." See "PhRMA Statement on New Hampshire Prescribing Data Legislation."Yes, prescribing data could be used that way and it could make drug safety surveillance much more efficient. Unfortunately, the information is not used that way. Pharmaceutical companies notoriously engage in non-targeted physician marketing (see, for example, "A Crisis in Professional Detailing"), so why would they be any better when it comes to notifying physicians of problems with their drugs? The best they can do is send "Dear Doctor" letters to ALL physicians who may (or may not) prescribe their drugs. In fact, this is what the FDA requires!
The PE article authors also argue that physician prescribing data can:
"Give physicians a unique view of their own practice HIOs [ie, IMS and companies like them] are piloting information products to physicians (as recommended in the 2004 AMA board report) that can reveal important facts about a physician's own practice: the degree to which patients comply and persist with treatment, patients' use of generics, and how the physician's prescribing practices compare with those of his or her peers. The data can also be used to provide valuable information for pay-for-performance systems that drive improved clinical practices."This is true, but irrelevant to the case of use of Rx data by pharma companies for marketing purposes (the NH law, for example, would not prohibit use of Rx data for these purposes).
Use of Rx data to measure physician performance and pay for that performance is a whole 'nuther can of worms that IMS should have been smart enough to leave unopened! Physicians hate HMOs and performance measures probably more than they hate pharma marketers. This issue, in fact, is one which aligns pharma and physician interests -- pharma is leery of evidence-based performance measures because they could hurt sales of their expensive drugs, which may be no more effective than generics. IMS and AMA, by using this argument, are not doing the industry any favors nor does it help the industry build better relations with its physician customers.
OK. Those were the unproductive arguments. Here's the laughable argument:
"...what is not widely known is that the pharmaceutical industry's commercial interest in the data ultimately makes possible a variety of other research applications. The industry underwrites the substantial costs that HIOs incur when collecting and processing the information. Without this support, the data would not exist for use in:OMG! The whole healthcare system would come tumbling down! If the pharma industry is the only payer for these data, then we are surely going to Hades! Where's government? Where's the insurance companies? Isn't their money any good? What is IMS saying? That it overcharges the pharma companies to subsidize giving away this information to the government and insurance companies? And the pharma industry has never crowed about this and taken credit for it? What's up with that PhRMA?
- Evidence-based drug safety studies
- Public health monitoring to set and promote public health policy
- Outcome studies and pharmacoeconomic analyses that look at value vs. cost
- Bioterrorism surveillance
- Development of clinical practice guidelines
- Disease management programs
- Analysis of changes in government healthcare programs (e.g., the uptake of Medicare Part D coverage)."
My conclusion: The cafeteria of arguments IMS and AMA offer against limiting use of Rx data for marketing purposes goes beyond the real issue (marketing) and is more self-serving than it serves the pharmaceutical industry.
What's Your Opinion?
Take the following survey, which solicits your opinion on the benefits of pharma access to prescribing information, physicians ability to opt-out, and appropriate uses of Rx data by pharmaceutical companies.
- After completing the survey you will be able to see a summary of results (de-identified, excludes open-ended responses and comments that may identify the respondent). You can also use filters to examine results from different subsets of respondents (e.g., pharma company employees vs. non-pharma people, etc.).