UCPMP 2024: building the evidence behind the self-declaration
The executive head signs the declaration. The evidence behind it has to come from testing every rupee spent on healthcare professionals.
The Uniform Code for Pharmaceutical Marketing Practices 2024 sets clear limits: no gifts or personal benefits to healthcare professionals or their families, a cap on free samples, CMEs held only in India with spend disclosed, and an annual self-declaration by the company's executive head.
A declaration is only as strong as the testing behind it. Camps, CMEs, speaker fees and samples are spread across divisions, agencies and thousands of field claims, so the evidence has to be assembled deliberately.
What a defensible review covers
- Health, screening and diagnostic camps tested for need, attendance, vendor bills and cost per beneficiary.
- Unannounced live monitoring of CME events against approvals.
- Speaker, advisory and research fees tested for genuine need and fair market value.
- Samples reconciled to prescriber, pack count and the cap; brand reminders within limits.
- Field-force claims tested against tour plans, CRM call logs and geo-tagged visits.
- Event agencies, liaison agents and distributors risk-rated against the Code.
The same evidence base supports exposure under the Prevention of Corruption Act, the US FCPA and the UK Bribery Act for companies with export or global exposure, and it answers the questions an audit committee will ask.
Facing a similar question? Speak to the partner who leads this work.
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