Decision

8 February 2016: Bloc Group Limited promotional scheme to healthcare professionals

Published 22 March 2016

Bloc Group Limited’s proposed promotional scheme for healthcare professionals was brought to the attention of MHRA. Independent pharmacies were offered points on the purchase of medicines. These points accumulated on a card and were available for personal spending by the cardholder.

MHRA considered the scheme to breach regulation 300(1) of the Human Medicines Regulations 2012. Bloc Group Limited decided to cease trading with immediate effect.

0.1 MHRA advice

Regulation 300(1) provides that “a person may not, in connection with the promotion of medicinal products to persons qualified to prescribe or supply them, supply, offer or promise to such persons any gift, pecuniary advantage or benefit unless it is- (a) inexpensive; and (b) relevant to the practice of medicine or pharmacy”.

The use of financial measures relating to prices, margins and discounts as part of the promotion of medicine to PQPS is not prohibited provided all transactions are clearly identifiable, invoiced and auditable through the business. A promotional scheme that offers personal benefits based on purchases of medicines would be prohibited under the Regulations.

It is also an offence under regulation 300(4) for a healthcare professional to “accept any gift, pecuniary advantage, benefit or hospitality that is prohibited by this regulation.”