The 2024 ABPI Code - Key changes

8th October 2024 by Felix Jackson

It is no small achievement for the PMCPA to publish the new 2024 ABPI Code with very significant changes that have taken years of careful planning and stakeholder engagement to achieve. Each change is exceedingly complex, involving minute adjustments that impact millions of people's healthcare. There are thousands of stakeholders who's day to day jobs might be significantly changed (or even entirely disappear!) due to new changes. So, the stakes are extremely high and mistakes must not happen. 

The latest Code updates are the most significant in two decades (well, as I remember since I've been a pharmaceutical medic), yet have little that needs to be done before 1st January 2025, as great care has been taken to minimise the immediate impact, while still offering significant future opportunities. 

medDigital is a general affiliate member of the ABPI, and I am our representative on the ABPI Code Working Group and Compliance Network. I was one of about 40 people representing lots of different organisations on the Code Working Group that proposed the main changes. I was closely involved in the changes to Clause 12 and the new QR Prescribing Information, and I am very proud of our work. We helped develop a much better and simpler solution to a major problem the Industry faced, without the need to change current practices or having to make changes to the law that would have take even longer to do.

The Working Group's proposals for Clause 12 were significantly improved by the PMCPA, ABPI and MHRA following consultation. They cleverly switched the perspective from the materials being provided to the use of the materials by professionals, demonstrating that they really do listen during the consultation and really think carefully about what changes mean to the Industry, professionals and patients. 

Please see a recording of medDigital's webinar about the changes:

All the changes are neatly summarised on the PMCPA website with links to all key documents.

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But, here is my quick summary of the key changes, but please watch the highlights of our webinar about the changes for more details! 

1. QR Prescribing Information (QRPI) - Clause 12

You can have a QR code with a 'scan for [medicine] PI' statement that links directly to the prescribing information on all materials that are provided or shown. If you add a hyperlinked, short URL this can also meet the requirement for materials that are accessed by the recipient (for example, the same version of slides with a QR code and a hyperlink can be shown in a meeting and then emailed to a doctor afterwards). Furthermore, all current methods of providing PI remain acceptable so no changes need to be made before 1st January 2025. QR codes can be added in time!  

2. Provision of AE reporting information - Clause 12.6

It is now sufficient to have a prominent statement indicating where AE reporting information can be found, rather than having to have the entire AE reporting details located prominently. This can be combined with the 'scan me for PI' statement near the QR code to meet both requirements. So, 'scan the QR code below for [medicine] PI and AE reporting' works for both!

3. Abridged Complaints Procedure

Although there are lots of changes to the Constitution and Procedures which help the PMCPA do their work more efficiently, transparently and independently, the headline change is adding in a new abridged procedure that enables clear breaches for certain clauses to be 'fast tracked' so they don't need to go through the full process. I think this was in response to the number of breaches with company employees re-sharing content in social media inappropriately, so they needed a way to deal with complaints like these more effeciently. 

4. Education Needs Assessment - Clause 10.3 & 10.4

You need to have a documented educational needs assessment for every individual that is supported to attend an event or meeting with the reason for the decision. So, if you want to pay for someone to go, you need to document why before you send them.  

5.  High Standards - Clause 5.2

A neatening up of the 'maintaining high standards' clause to make sure it applies to all company personnel (not just the company itself and sales reps). Nice to have, but we knew this already. I suspect it will be added to all complaints to catch staff as well as companies who might behave badly!  

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And, there are other changes that are also important, such as clarifying that the disclosure template is mandatory, so watch the highlights of our webinar to see them all.  

Please get in touch if you have any questions or if we can help you with implementing these changes. We've already had a lot of questions about how to implement the QRPI in practice! 


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