Transport

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific rules
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Legislation: Not applicable.

MA Code of Conduct

Prescription pharmaceutical companies may sponsor travel for HCPs attending an international educational event in either economy or business class.  Domestic air travel within Australia, and international air travel to New Zealand is by economy class only.

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

Restriction on train transportation (class; duration; etc.)

Legislation: Not applicable.

MA Code of Conduct

No specific restrictions on train transportation.  Intercity business travel by train is not common in Australia.

Other restrictions regarding travel

Legislation: Not applicable.

MA Code of Conduct

Prescription pharmaceutical companies may provide travel to HCPs only in direct association with educational event/s or to undertake a consulting service.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy class air travel only in case of flights within Europe. Business class tickets may be offered in case of flights outside Europe (i.e. intercontinental flights).
Restriction on train transportation (class; duration; etc.) Up to and including first class tickets are permitted; premium class is not allowed.
Other restrictions regarding travel Reasonable travel expenses.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific rules.
Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel No specific rules.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Economy class air travel only. Exceptionally, business class air travel may be allowed where the following conditions are met:

  • The HCPs participate in the scientific event as a consultant;
  • The outward and/or return flight is longer than six hours, excluding flyovers.
Restriction on train transportation (class; duration; etc.) Economy and Business class allowed.
Other restrictions regarding travel Transfers from home to the airport and/or railway station cannot be offered or reimbursed to HCPs participating to the scientific event, unless participating as consultant.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Statutory Laws

No specific rules. Any specifics must be assessed on the case-by-case basis.

INTERFARMA

The offering of first-class tickets for Healthcare Professionals or Healthcare-related Professionals is not allowed.

SINDUSFARMA

No specific rules. Any specifics must be assessed on the case-by-case basis.

ABIMIP

No specific rules. Any specifics must be assessed on the case-by-case basis.

Restriction on train transportation (class; duration; etc.) No specific rules. Any specifics must be assessed on the case-by-case basis.
Other restrictions regarding travel

Statutory Laws

No specific rules. Any specifics must be assessed on the case-by-case basis.

INTERFARMA

Expenses with transportation are limited to the event itself and are related solely to the invited professional, and may be extended to the days immediately before and immediately after the official agenda, in case logistics and transport issues justify such extension.

SINDUSFARMA

Members can sponsor or reimburse expenses with travel tickets of the health area professionals in national and international events, during the period of the event, which can be extended to the days immediately prior to or after the official agenda, for logistics, locomotion and transportation purposes that will justify granting this sponsorship.

ABIMIP

No specific rules. Any specifics must be assessed on the case-by-case basis.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Not applicable
Restriction on train transportation (class; duration; etc.) Not applicable
Other restrictions regarding travel In case of CME events, only ‎reimbursement of travel expenses ‎allowed provided that the HCP is a ‎recognized expert in the field and ‎he/she provides a substantive ‎educational session within the ‎event. ‎

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy class air travel only.  Exceptionally, a different class may be offered to HCPs hired as consultant and in accordance with the company’s internal policies.
Restriction on train transportation (class; duration; etc.) Not applicable.
Other restrictions regarding travel No travel expenses may be offered to HCPs who are resident in the city where the event is held.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Statutory Laws and Regulations

No specific rules.

Codes of Conduct

Code of Ethics for Chinese Medical Doctors

No specific rules.

RDPAC Code

Member companies may pay for transportations that are appropriate for the meeting destination, but should avoid extravagant transportation services (Article 7).

AdvaMed China Code

Companies may provide for reasonable flights and incidental expenses for HCP travel. Companies  are  encouraged  to  pay  for  flights directly  where practical.  Reimbursement of travel-related expenses over RMB 500 should not be made in cash (Article IX).

Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel No specific rules.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing travel and transportation payments that exceed one (1) minimum monthly wage during a six-month period to the same recipient must be reported. 

The minimum monthly wage for 2020 is: COP $877.803 or approximately USD $260. 

The six-month periods go from January to June, and July until December of each year.

AFIDRO'S Code of Ethics: Hospitality sponsorship may only include guest’s travel costs, which must be moderated and reasonable, no distinction is made for air travel. 

ANDI's Code of Ethics and Transparency: It sets the same standard as AFIDRO’S Code of Ethics.

Restriction on train transportation (class; duration; etc.)

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing travel and transportation payments that exceed one (1) minimum monthly wage during a six-month period to the same recipient must be reported. 

The minimum monthly wage for 2020 is: COP $877.803 or approximately USD $260. 

The six-month periods go from January to June, and July until December of each year. 

AFIDRO'S Code of Ethics: Hospitality sponsorship may only include travel costs of the guest, which must be moderated and reasonable, no distinction is made for train travel. 

ANDI's Code of Ethics and Transparency: It sets the same standard as AFIDRO’S Code of Ethics.

Other restrictions regarding travel

RTVSS: None. 

AFIDRO'S Code of Ethics: None. 

ANDI's Code of Ethics and Transparency: None.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

The Ordinance: no specific provisions, see general rules above.

The Code: as a main rule, travel expenses may be paid only for economy class air travel. Exceptionally, business class shall be also deemed acceptable, provided that the flight in one direction from the place of residence of the participant of the event to the venue exceeds 4 hours in continuity.

Restriction on train transportation (class; duration; etc.)

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules.

Other restrictions regarding travel

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

No specific rules.

Restriction on train transportation (class; duration; etc.)

No specific rules.

Other restrictions regarding travel

No specific rules.

Please also see European Union.

Last modified 23 Mar 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Economy class air travel maximum for flights within Europe and premium economy air class travel for oversea flights maximum. Business class air travel may exceptionally be allowed by ENLI. Business class is acceptable in all instances where the traveler is wheel-chair bound or otherwise disabled.

Air travel in First Class (where First Class is at a level above Business Class) is never permitted (ENLI, Guidance on "The Pharmaceutical Industry's Code of Practice on Promotion etc., of Medicinal Products aimed at Healthcare Professionals" (The Promotion Code), p. 62). 

Restriction on train transportation (class; duration; etc.) Travel by train is considered as transport at a reasonable level – regardless of the choice of "class". However, this is provided that the train journey does not take place at a significantly expensive level, that reflects luxury or extravagance (ENLI, Guidance on "The Pharmaceutical Industry's Code of Practice on Promotion etc., of Medicinal Products aimed at Healthcare Professionals" (The Promotion Code), p. 62).
Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 12 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Directive

No specific rules.

EFPIA

No specific rules.

IFPMA

No specific rules.

Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel

No specific rules.

Last modified 23 Mar 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation.

Restriction on train transportation (class; duration; etc.)

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation.

Other restrictions regarding travel

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

StGB

No specific rules. However, the general principles outlined above apply.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Air travel is permitted if and to the extent appropriate and necessary for the arrival and departure at the venue (on the most direct route possible). Generally, only economy class air travel is permitted for intra-European flights. Business class air travel is permitted for intercontinental flights. First class air travel is generally not appropriate.

Restriction on train transportation (class; duration; etc.)

StGB

No specific rules. However, the general principles outlined above apply.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Train travel is permitted if and to the extent appropriate and necessary for the arrival and departure at the venue (on the most direct route possible). First class train tickets are generally considered appropriate.

Other restrictions regarding travel Car travel costs equal to the tax-allowed kilometers for business trips in Germany and the reimbursement of taxi costs or public transport costs (to and from the event location) are permitted.

Please also see European Union.

Last modified 22 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Economy class air travel only.  Exceptionally, business class tickets may be offered in case of flights lasting for at least four hours.

Restriction on train transportation (class; duration; etc.)

No specific rules

Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 26 Mar 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

The Prevention of Bribery Ordinance

No specific rules. 

HKAPI Code of Practice

Standard economy class should be provided to professionals for one-way flight time of 5 hours or less (para 5.2(a)).

Standard economy class should also be the prioritised consideration for one-way flight time of more than 5 hours (and not include any travel or other sponsorship for their family members or companions) (para 5.2(a)).

Gratuitous payments in cash (equivalents), including free flight upgrades, must not be offered to HCPs under any circumstances (para 6.1). 

Code of Conduct

No specific rules.

Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel

The Notice

A prescribed officer may accept any air, sea or overland passage given to or made available to him in his private capacity by a tradesman, firm, company, organisation or association by virtue of:

  • the terms on which his spouse/parent/child is employed
  • his membership of any organisation/association
  • his or his spouse/ parent/ child being  regular customer, or
  • in the normal course of business  (s. 4(1))

The above permission only applies if the advantage is equally available on equal terms to persons who are not prescribed officers, and if the donor of the advantage has no official dealings with the prescribed officer.

Last modified 21 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Lowest air class available.
Restriction on train transportation (class; duration; etc.) Lowest train class available.
Other restrictions regarding travel Not applicable

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy class air travel only should be offered for flights of less than five hours. 
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 9 Apr 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy-class air travel only.  Exceptionally, business class tickets may be offered in case of intercontinental flights of more than six hours and only for speakers or moderators included in the official program of the event, to the exclusion of those only presenting posters.
Restriction on train transportation (class; duration; etc.) All classes allowed except for Executive class.
Other restrictions regarding travel Not applicable

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

FCC and its guidelines

Air travel sponsored by pharmaceutical companies for HCPs as a means of unjustifiably inducing purchases of pharmaceutical drugs is prohibited.

However, reimbursing transport expenses incurred for business activities that pharmaceutical companies delegate to HCPs with objectively reasonable purposes are not restricted under the FCC.

Restriction on train transportation (class; duration; etc.)

FCC and its guidelines

Same as air travel.

Other restrictions regarding travel Not applicable

Last modified 2 Feb 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

In case of flights of less than six consecutive hours, only lowest class offered. In case of flights of six or more hours (excluding flyovers) where two classes are available, either class. However, in cases of flights of six or more consecutive hours where three or more classes are available, the best offered class may not be offered.

Flexible flight tickets may only be offered if there is adequate justification (e.g. luggage fees or because the activity may end sooner than expected) and must be accompanied by a statement that the flexibility will not be used to make changes to accommodate personal travel.

Restriction on train transportation (class; duration; etc.) Economy or Standard Business classes allowed only.
Other restrictions regarding travel EUR 0,40 per km maximum in case of car transfers.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Provisions in this sense remain ambiguous: round trip transportation costs shall be reasonable (at CETIFARMA's discretion in accordance to regular standards) and not exceed the cost that HCPs would be willing to cover under similar circumstances.
Restriction on train transportation (class; duration; etc.) Please refer to air travel restrictions above, as they are equally applicable.
Other restrictions regarding travel Not applicable

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) In principle only economy class. Business class may only be compensated for intercontinental flights.
Restriction on train transportation (class; duration; etc.) First class train tickets may be compensated.
Other restrictions regarding travel

Additionally, compensation for travel may occur as following:

Car: 0.37€ /km;

Taxi: full in addition to public transport.

Compensation for travel time may only be for time during working hours.  Compensation for preparation may be paid, however both Travel Time and Preparation cannot both be paid.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Medicines New Zealand Code of Practice

  • Flights must be booked directly by the sponsoring company, unless that would be impracticable.
  • Domestic travel must be economy class.
  • International travel may be business class where the flight exceeds 5 hours.  First class travel is prohibited.
Restriction on train transportation (class; duration; etc.)

There are no relevant restrictions relating to train travel in particular.

Intercity business travel by train is not common in New Zealand.

Other restrictions regarding travel

Medicines New Zealand Code of Practice

  • Travel may be provided only if the meeting content relates to the HCP's area of expertise, their origin justifies reimbursement, and the expenses are verified.

Royal Australian College of Physicians Guidelines

  • Generally, attendees should meet the cost of travelling to pharmaceutical industry events.
  • If HCPs do accept financial support to meet the costs of travelling, they should be satisfied that this will not lead to a perceived loss of professional independence.

Last modified 10 Jun 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Norwegian Pharma Law

No specific rules.

LMI Industry rules

No specific rules except the general extravagant or luxurius test referred to under Event venue.

Restriction on train transportation (class; duration; etc.)

Norwegian Pharma Law

No specific rules.

LMI Industry rules

No specific rules except the general extravagant or luxurius test referred to under Event venue.

Other restrictions regarding travel

Norwegian Pharma Law

No specific rules.

LMI Industry rules and Agreement between the pharmaceutical industry and the regional hospitals

It is not allowed to pay for travel and/or accommodation for HCPs from Norway to participate in third party events in countries outside of Norway ("congress ban"). It is also prohibited to pay for travel and accommodation for HCPs from public hospitals (No. helseforetak) to participate in events (whether local or international).

Last modified 16 Feb 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Polish Pharmaceutical Law

No specific rules.

INFARMA

No specific rules.

PZPPF

Flights must be booked in economy class; business class flights may only be refunded in exceptional circumstances where justified.

Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel

Polish Pharmaceutical Law

No specific rules.

INFARMA

No specific rules.

PZPPF

Travel should always be on the most direct and logical route, taking into account the costs to the enterprise. Breaks in travel, side trips and travel extensions financed or facilitated by the company are prohibited.

As far as it is possible from a logistical point of view, arrivals and departures should coincide with the beginning and end of the meeting.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy-class air travel only.  Exceptionally, business class tickets may be offered following assessment on a case-by-case basis, particularly considering flight duration.
Restriction on train transportation (class; duration; etc.) Economic class travel only. Exceptionally, business class tickets may be offered following assessment on a case-by-case basis, particularly considering trip duration.
Other restrictions regarding travel Travel expenses must be directly paid by travel agencies appointed by the pharmaceutical companies.

Please also see European Union.

Last modified 5 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

No specific rules.

Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel No specific rules.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Economy class air travel only.
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Under Pharmaceutical Law, Organizations are prohibited to pay for transportation to the leisure location.
Restriction on train transportation (class; duration; etc.) Under Pharmaceutical Law, Organizations are prohibited to pay for transportation to the leisure location.
Other restrictions regarding travel Under Pharmaceutical Law, Organizations are prohibited to pay for transportation to the leisure location.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No restrictions identified.
Restriction on train transportation (class; duration; etc.) No restrictions identified.
Other restrictions regarding travel No restrictions identified.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific rules
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific rules
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific criteria have been published with regard to the transportation requirements/standards. Applying analogically the criteria established for the accommodation venue, we consider that the transportation shall be always booked in an economy class to the extent possible.
Restriction on train transportation (class; duration; etc.) The same response above applies.
Other restrictions regarding travel

The companies will be directly responsible for the payment of the necessary expenses (airplane tickets or train, etc.). No monetary reimbursement can be made to the HCPs for expenses incurred that come from suppliers that should have been paid directly by the pharmaceutical company, except in the case of minor travel expenses (cabs, mileage, etc.) with due justification of the same.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No travel expenses may be paid for HCPs attending events (meetings and congresses etc.).  Exceptionally, economy class air travel may be provided to HCPs engaged as consultants. In such instance, business class air travel may be allowed in case of flights outside Europe lasting for more than six hours.  
Restriction on train transportation (class; duration; etc.) See above.
Other restrictions regarding travel Travel should be arranged so that arrival and departure is as close as possible to the opening and closing of the consultancy assignment at the event.

Please also see European Union.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) Class of travel should be in accordance with the management policy of the authority or facility where the healthcare professional practices.
Restriction on train transportation (class; duration; etc.) No specific rules.
Other restrictions regarding travel

If no management policy exists, class of travel depends on duration of the flight.

Medical product companies are expected to have pre-set thresholds for upgrading from economy to business and business to first class.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Subject to the below, companies should only offer or provide economy air travel to delegates sponsored to attend meetings. Delegates may organize and pay at their own expense the genuine cost of an upgrade. 

For flights that are scheduled to take longer than 6 hours, companies may pay for an upgrade from economy to premium economy or similar.

Restriction on train transportation (class; duration; etc.) Any hospitality must be provided at a subsistence level only, including "reasonable travel".
Other restrictions regarding travel Not applicable.

Last modified 15 Jan 2021

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class)

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" air travel, but enforcement action and settlement history show that selection is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that "compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer’s risk." 68 Fed. Reg. 23,721, 23,738 (May 5, 2003). See below. 

State Laws & Implementing Regulations: A number of states with laws of this type incorporate an expectation that travel expenses must be "reasonable" to be covered. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses. The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."

Restriction on train transportation (class; duration; etc.)

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" train transportation, but enforcement action and settlement history show that selection is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that “compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer’s risk.”  68 Fed. Reg. 23,721, 23,738 (May 5, 2003).  See below. 

State Laws & Implementing Regulations: A number of states with laws of this type incorporate an expectation that travel expenses must be "reasonable" to be covered. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses.  The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."

Other restrictions regarding travel

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" travel considerations, but enforcement action and settlement history show that selection is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that "compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer's risk." 68 Fed. Reg. 23,721, 23,738 (May 5, 2003). See below. 

State Laws & Implementing Regulations: Some states detail restrictions on payments for travel for non-faculty HCPs.  For example, New Jersey prohibits any payment or direct subsidy to a non-faculty prescriber for the costs of travel associated with attending any education event or promotional activity. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses.  The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Relevant statutory law(s)

Resolution of the Ministry of Health 627/2007

Industry code(s) of conduct

Code of good practices of Argentine Chamber of Medical Specialties (CAEME)

Other Not applicable

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Competent authority/authorities enforcing the above statutory law(s)

Argentinian Ministry of Health

Competent authority/authorities enforcing the above code(s) of conduct Argentine Chamber of Medical Specialties (CAEME)
Competent authorities enforcing any other provisions indicated above Not applicable

 

Last modified 15 Jan 2021

Argentina

Argentina

Topic Detail
Restrictions on event locations (e.g., events abroad, touristic locations, mountain or beach locations during winter/summer season, etc)

No event should take place outside the Argentine Republic, unless there are logistical or security reasons for holding it abroad (e.g. where most of the participants guests come from abroad and/or where the relevant resource or expertise is located abroad).

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Restrictions or requirements regarding event venues (e.g., resorts, castles, SPAs, proximity to transport connections or centers with relevant medical expertise, etc)  

Luxurious venues should not be selected for hosting events.

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Restrictions or requirements regarding accommodation provided to HCPs (e.g. five star hotels, maximum number of nights, minimum duration of events, etc.) Accommodation may be provided to HCPs only and it should not include sponsorship or organization of entertainment or leisure activities (e.g. sporting events, musical events, etc.).

Last modified 15 Jan 2021

Argentina

Argentina

Topic Detail
Restrictions on air travel (e.g. economy class only; minimum flight duration for business class) No specific rules
Restriction on train transportation (class; duration; etc.) No specific rules
Other restrictions regarding travel No specific rules

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Limitation on providing meals (e.g. only refreshment for events lasting for half a day or more) No specific rules
Maximum value for meals (e.g., EUR 60) – please specify by meal (breakfast, lunch, dinner) where applicable No specific rules
Restrictions on where meals can be provided? (e.g. no Michelin-starred restaurant) No specific rules
Other restriction (e.g. no alcohol may be offered) No specific rules

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Rules applicable to family members travelling together with HCPs to the event location. No specific rules

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Rules originally designed for traditional events (described in previous points) but applicable also to online conferences No specific rules
Additional rules applicable specifically to online conferences (incl. communication / advertising rules in relation to events attended by multinational audience) No specific rules

Last modified 15 Jan 2021

Argentina

Argentina

Topic Details
Specific rules applicable to promotional events organized by/on behalf of MAH in comparison to independent scientific events described in previous points (incl. event location, venue, accommodation, transport, meals, family members, online conferences No specific rules

Last modified 15 Jan 2021