UCPMP compliance and HCP spend assurance
Evidence that every rupee spent on healthcare professionals complies with UCPMP 2024, ready to support the executive head's annual self-declaration.
Testing of every rupee spent on healthcare professionals against UCPMP 2024, with evidence for the annual self-declaration.
The Uniform Code for Pharmaceutical Marketing Practices 2024 bars gifts and personal benefits to healthcare professionals and their families, limits free samples and brand reminders, and requires CME and CPD events to be held in India with spend disclosed. The company's executive head signs a self-declaration of compliance each year.
A declaration is only as strong as the testing behind it. We review camp expenses and monitor CME events live, test speaker and consultancy fees for genuine need and fair market value, reconcile samples to prescribers and limits, and audit field-force claims against tour plans and call records. Event agencies, distributors and consultants are risk-rated against the Code.
For companies that sell in the United States, we extend the work to Sunshine Act (Open Payments) reporting, so that payments to US covered recipients are captured and reported accurately.
Your pharmaceutical business must evidence that its spending on healthcare professionals complies with UCPMP 2024.
Signs we see most often
- 01The executive head must sign the annual UCPMP self-declaration.
- 02HCP engagement runs through many divisions, agencies and field claims.
- 03A complaint has been made to an Ethics Committee for Pharma Marketing Practices.
- 04Camp, CME or sample spend has grown without matching evidence.
- 05You report payments to US healthcare professionals under the Sunshine Act.
Scoped in writing, run by one accountable team.
Every engagement starts with agreed questions, a reporting line and a confidentiality protocol. The steps below are how this service usually runs; we adapt them to your matter.
- 01MapIdentify every channel of HCP spend across divisions, agencies and the field.
- 02MonitorAttend CME events unannounced and test camps against need and attendance.
- 03TestExamine fees, samples, brand reminders and claims against the Code's limits.
- 04AnalyseRun red-flag analytics across expense, CRM and event data.
- 05RateRisk-rate event agencies, distributors and consultants.
- 06EvidenceAssemble the pack that supports the self-declaration and any Sunshine Act filing.
Assurance, and evidence, that HCP spend complies with the Code, and with the Sunshine Act where you sell in the US.
- An HCP spend testing report with exceptions
- Live monitoring reports on CME events
- Risk ratings for agencies, distributors and consultants
- An evidence pack for the annual self-declaration
- Sunshine Act (Open Payments) reporting assurance for US operations
The law and frameworks this work is aligned to
- Uniform Code for Pharmaceutical Marketing Practices 2024, Department of Pharmaceuticals
- Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002
- Supreme Court in Apex Laboratories v. DCIT (2022) on the tax treatment of freebies to doctors
- US Physician Payments Sunshine Act (Open Payments)
- Prevention of Corruption Act, 1988, US FCPA and UK Bribery Act, where they apply
References show the standard the work is built to. They do not imply accreditation or endorsement by the bodies that publish them.
This is a summary of the service. For a deeper understanding of how it would work for your organisation, please reach out to us.
Talk to a BDI partnerQuestions clients ask before we start.
Who enforces UCPMP 2024?
Complaints are heard by Ethics Committees for Pharma Marketing Practices set up by industry associations, with appeals to an Apex Committee at the Department of Pharmaceuticals. The Code also requires an annual self-declaration from each company's executive head.
Can you test field-force claims at scale?
Yes. Claims are matched against tour plans, CRM call logs and geo-tagged visits across the full population, so exceptions are found rather than sampled.
Does the work cover medical devices?
The same approach applies to the Uniform Code for Marketing Practices in Medical Devices 2024, which follows a similar structure.