Consultation outcome

Government response: the disclosure of industry payments to the healthcare sector

Updated 18 December 2025

References to ‘government’ in this document relate to the UK government in Westminster. Officials of the devolved nations have been closely involved in this work.

Background

The life sciences industry is crucial to the nation’s health, developing innovations in medicines and medical devices that improve citizens’ quality of life across the UK. To achieve this, industry works closely with leading hospitals, clinicians and researchers to develop products and ensure these are used safely and effectively.

These relationships sometimes involve the provision of payments and benefits by industry such as research grants, training events and reimbursement for work such as testing and consultancy.

Published in July 2020, the First Do No Harm report of the Independent Medicines and Medical Devices Safety (IMMDS) review, led by Baroness Cumberlege, investigated 3 medical interventions that resulted in adverse consequences:

• hormone pregnancy tests (HPTs) - tests, such as Primodos, which were withdrawn from the market in the late 1970s and which are thought to be associated with birth defects and miscarriages
• sodium valproate - an effective anti-epileptic drug which causes physical malformations, autism and developmental delay in many children when it is taken by their mothers during pregnancy
• pelvic mesh implants - used in the surgical repair of pelvic organ prolapse and to manage stress urinary incontinence. Their use has been linked to crippling, life- changing, complications

The government at the time accepted the overarching conclusion of the IMMDS report: that the system failed to listen to patients or put patients at the centre of their care.

Subsequent work has focused on:

• improving how the system listens to and responds to concerns raised by patients
• strengthening the evidence base on which decisions are made, including through making sure the right data is collected and used
• improving the safety of medicines and devices

As detailed in the government’s response to the IMMDS report, the previous government accepted 7 of the 9 recommendations in full, in part or in principle. Four of these have been successfully implemented, including:

• issuing an unreserved apology on behalf of the healthcare system
• appointing the first ever Patient Safety Commissioner in England in respect of medicines and medical devices
• establishing 9 specialist mesh centres, which are in operation across England
• establishing and working with a Patient Reference Group to help develop the response to the IMMDS review

As part of the eighth recommendation, the IMMDS review raised concerns about the conflicts of interest, both real and perceived, in the provision of care or treatment of patients, where clinicians have financial links with pharmaceutical and medical devices companies.

The IMMDS review stated:

We have heard particular [patient] concerns that clinicians have been paid or otherwise incentivised by manufacturers. This may influence their practice, and the course of action they recommend to patients, such as preferentially using particular procedures or drugs.

The IMMDS review acknowledged the Association of the British Pharmaceutical Industry’s (ABPI) Disclosure UK system, which publishes information about payments and benefits in kind made by pharmaceutical companies abiding by the ABPI code to the healthcare sector. In 2025, 151 companies made declarations through Disclosure UK. The IMMDS report highlighted that there is no similar system in place for the medical device sector in the UK.

The IMMDS review stated:

Medicines and medical device manufacturers should… ensure that they publish details of payments and payments in kind that they make to teaching hospitals, research institutions and individuals.

Since the government’s response to the IMMDS review, we have considered ways to strengthen industry reporting requirements through engagement with:

• patients
• professional regulators
• clinicians
• academics
• trade associations
• industry

We know that medicines and medical device trade associations have codes of conduct in place that set standards for how businesses should engage with researchers and healthcare providers. These supplement professional codes of conduct that healthcare professionals are required to follow.

In 2023, the then government launched a public consultation to seek the views of individuals and organisations in relation to disclosure of industry payments to the healthcare sector.

This document provides an overview of the responses received as part of the consultation, and how the responses have informed government plans to address the issues raised.

Summary of responses

An online public survey was developed for respondents to provide their views on the questions posed as part of the government consultation. It was open for a duration of 6 weeks from 4 September to 16 October 2023. This survey was actively shared with important stakeholders to ensure those with particularly relevant views or experience had the opportunity to contribute. In total, 690 responses were received, with 609 received through the survey and 81 received by email.

Of the 609 survey responses:

• 423 (69.5%) were individuals sharing their personal views and experiences (‘individuals’)
• 100 (16.4%) were individuals sharing their professional views (‘professionals’)
• 83 (13.5%) were responding on behalf of an organisation (‘organisations’), including trade associations and private businesses
• 3 (0.5%) were responding as academics or researchers (‘academics’)

Table 1: survey responses by devolved nation

Respondent category	England	Scotland	Wales	Northern Ireland	I live outside of the UK	Not specified
Individuals	332	52	16	9	11	3
Professionals	79	6	5	1	9	0
Organisations	0	0	0	0	0	83
Academics	0	0	0	0	0	3

In addition to the online survey, 81 email responses were received and formally considered as part of this consultation. Where comments or opinions expressed in email responses were felt to align clearly with a standardised answer (such as ‘agree’) to a specific survey question, they were integrated into the quantitative analysis as ‘individuals’.

Where comments or opinions contained information relevant to the question’s theme, but were not felt to align clearly with a standardised answer, they were included for qualitative analysis in the free text response analysis sections.

It should be noted that of the 81 emails, 65 were received as part of a campaign. Although there were variances in these emails, many followed a similar format. For clarity, a specific reference has been made alongside any question where these campaign emails were included in the quantitative analysis.

The majority (91.6%) of respondents, across response categories, agreed with the proposal to require publication of information about payments or other benefits to persons or organisations connected to the provision of healthcare (both public and private).

Respondents generally felt the scope of such obligations should be wide and apply to a broad range of individuals or organisations involved in healthcare more generally. While there was support (74.3%) for proposals to require business to publish payment information on their website’s UK homepage, a significant number of respondents advocated for a single, central, government-held public database.

Respondents were generally in favour (72.8%) of government-led compliance monitoring and financial penalties (55.1%) as an effective deterrence for non-compliance. Some respondents, however, were sceptical of voluntary reporting and felt mandatory reporting was preferential.

The ‘Data analysis’ section provides a more detailed evaluation of the responses to each of the survey questions.

Government response

The government wishes to express its gratitude to all of those who contributed to this consultation, and their patience while the analysis and response was finalised.

It is clear from the majority of responses that there is a need for better transparency regarding payments made between industry and:

• registered healthcare professionals
• healthcare provider organisations
• organisations connected to the provision of healthcare

The government fully supports this sentiment, recognising the importance in enabling patients to make informed decisions about their own care and improving the transparency of industry payments.

In response to this consultation, the government will develop and publish clear guidance in relation to disclosing payments made by the medicines and medical devices industries to the healthcare sector. This guidance will set out best practice for industry to follow, which will advise on:

• which payments should be reported
• the format of the reporting
• the frequency of the reporting

The government will monitor the uptake of this forthcoming guidance.

While the government acknowledges that a number of stakeholders favoured a legislative approach to payment disclosures, this guidance-based approach will allow patients to benefit from industry reporting more quickly, without further delays that could have followed the introduction of legislation and the establishment of a government reporting and compliance system. This positive step towards transparency will add clarity to the relationship between industry and healthcare professionals, assisting patients in making informed decisions about their care.

Over the coming months, officials will work with stakeholders to develop a robust set of guidelines, with careful consideration given to the range of valuable suggestions provided by respondents to the consultation. This will ensure that the guidance is comprehensive and captures all relevant payments to healthcare-related professionals.

To date, no formal government guidance has been available for industry to follow and against which patients can hold the sector to account. This step will provide certainty for industry and stakeholders, as well as a clear path to improve transparency and improve public safety.

This decision is also aligned with the government’s commitment to reduce regulatory burden on industry. It will provide industry with the space to show leadership and a commitment to transparency, while minimising regulatory requirements that could be especially detrimental to small and micro businesses.

Conclusion

In making these decisions, the government has carefully reviewed the responses received as part of this consultation.

The government recognises the strength of opinion in this space and agrees with the importance of transparency and building a system where financial conflicts of interest are made public. The government firmly believes that the introduction of guidance will help create a culture of transparency and openness within the health sector, ultimately to the benefit of patients.

The plan outlined above will provide both clarity and a structure for industry to lead the way forward and evidence their commitment to patient safety and transparency.

It will also provide government with the necessary oversight to monitor progress and retain the option to take additional regulatory or legislative action, if required.

Data analysis

This section provides a breakdown of the responses to each of the survey questions.

As some respondents did not answer every question, or provided both a standardised response and a free text submission, figures will not always total 690.

Businesses that may need to publish information

Question 1: the government proposes to make the following businesses subject to this reporting duty: manufacturers and commercial suppliers of medicines, medical devices and borderline substances. Do you agree with this proposal? 

Of the 605 responses to this question:

• 551 agreed
• 17 disagreed
• 2 said they didn’t know
• 35 said they had an alternative suggestion

Table 2: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know	I have an alternative suggestion
Individuals	406	5	1	10
Professionals	84	9	1	6
Regulatory body	1	0	0	0
Organisations	58	3	0	19
Academics	2	0	0	0

There were 35 free text responses for question 1. A consistent theme across respondents was that a wider range of organisations should be included in the scope of any future reporting, such as:

• charities
• third party vendors
• private clinics
• veterinarians
• cosmetics and borderline product manufacturers
• manufacturers of commercial milk formula (CMF) for breastfeeding women
• providers of software and/or IT services

Four respondents from organisations requested a clear definition of what payments would be in scope in the case of borderline products specifically. Four individuals felt payments themselves were inappropriate and/or should be banned.

Recipients in scope

Question 2: the government proposes to require information about payments or other benefits provided to registered healthcare professionals, healthcare provider organisations and organisations connected to the provision of healthcare to be published, with regulations making no distinction between public or private sectors. Do you agree with this proposal? 

Of the 666 responses to this question:

• 610 agreed
• 26 disagreed
• 3 said they didn’t know
• 27 responded ‘other’

Table 3: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know	Other
Individuals	470	8	0	6
Professionals	83	12	2	3
Regulatory body	0	0	0	1
Organisations	56	6	1	16
Academics	1	0	0	1

Note that responses from individuals agreeing with this proposal include 63 campaign emails.

There were 27 free text responses for question 2. A general theme, across respondent categories, was a need for clarity in identifying professionals or organisations for which regulations would apply. Specific examples included:

• non-patient facing health-related professionals
• healthcare professional subgroups (such as psychotherapists)
• less clearly-defined groups, such as:
  • journalists
  • charities
  • patient advocacy organisations
  • professional bodies

Question 3: do you or your business currently make payments or provide other benefits to registered healthcare professionals and healthcare provider organisations? 

Of the 553 respondents to this question:

• 79 said yes
• 453 said no
• 21 said they didn’t know

Table 4: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	18	353	14
Professionals	15	72	6
Regulatory body	0	1	0
Organisations	46	26	1
Academics	0	1	0

Question 4: do you or your organisation currently receive payments or receive other benefits from manufacturers or suppliers of healthcare products? 

Of the 556 respondents to this question:

• 47 said yes
• 474 said no
• 35 said they didn’t know

Table 5: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	10	360	13
Professionals	21	59	17
Regulatory body	0	1	0
Organisations	16	53	5
Academics	0	1	0

Question 5: the government proposes to require information about payments or other benefits provided to any organisation involved in medical research or training to be published. Payments to charity arms of hospitals or similar organisations linked to healthcare providers should also be in scope. Which of the following organisations do you think should be included in the scope of these regulations? Please choose all the organisations you believe should be included (multiple answers permitted) 

There were 587 responses for this multiple-choice question.

Table 6: breakdown of responses by answer

Answer	Number of responses
Charity arms of hospitals	512
Medical or clinical research organisations (including medical research charities)	536
Professional bodies responsible for the core training of healthcare professionals (for example royal colleges, Membership of the Royal College of Physicians (MRCP))	548
Other medical education or training providers	527
Patient advocacy organisations	495
Don’t know	13
Other - please specify	111

There were 111 free text responses for question 5. A non-exhaustive list of additional examples included:

• MPs and government officials
• NHS trusts
• unregistered healthcare professionals (HCPs) or other HCPs not otherwise mentioned in earlier questions
• stoma nurses and the wider stoma industry
• IT providers and non-clinical staff involved in procurement
• professional associations
• health and medical journals
• research institutions
• academics

Operation of the duty

Reporting frequency

Question 6: the government proposes to require businesses to publish payment information on their websites with a link in a prominent place on the website’s UK homepage. Do you agree or disagree with this proposal?

Of the 666 responses to this question:

• 495 agreed
• 29 disagreed
• 9 said they didn’t know
• 133 said they had an alternative suggestion

Table 7: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know	I have an alternative suggestion
Individuals	383	8	4	90
Professionals	74	11	3	12
Regulatory body	0	0	0	0
Organisations	38	10	2	29
Academics	0	0	0	2

Note that responses from individuals stating they have an alternative suggestion includes 62 campaign emails.

There were 133 free text responses for question 6. A general theme, across respondent categories, was that payment information should be available through a central database or website. Seven respondents from organisations felt Disclosure UK or an equivalent scheme should remain an option for publishing disclosures. Six respondents from organisations also noted that not all companies had UK websites and would therefore like the option to publish elsewhere (such as European or global websites). Sixty-two campaign emails stated their preference for a single, central, government-held public database that is free for the public to access.

Question 7: the government proposes to require businesses to publish details of relevant payments and benefits annually on their websites with a link in a prominent place on the website’s UK homepage. What should the reporting frequency requirement be?

Of the 652 responses to this question:

• 249 said every 12 months
• 136 said every 6 months
• 150 said every 3 months
• 29 said they didn’t know
• 88 responded ‘other’

Table 8: breakdown of responses by respondent category

Respondent category	Every 12 months	Every 6 months	Every 3 months	Don’t know	Other
Individuals	143	115	126	21	74
Professionals	51	13	20	4	9
Regulatory body	0	0	0	0	0
Organisations	54	8	4	4	5
Academics	1	0	0	0	0

Note that responses from individuals answering ‘other’ include 63 campaign emails.

There were 88 free text responses for question 7. Among individuals and professionals, 9 respondents suggested reporting should be in real-time or in response to a significant change. Sixty-three campaign emails suggested the reporting frequency should be at least once a year.

Question 8: the government proposes to require businesses to report all relevant payments and benefits provided over the full year, if they supplied a product in scope at the beginning of the reporting cycle. Do you agree or disagree with this proposal?

Of the 589 responses to this question:

• 531 agreed
• 30 disagreed
• 28 said they didn’t know

Table 9: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know
Individuals	388	17	12
Professionals	81	10	8
Regulatory body	1	0	0
Organisations	61	3	8
Academics	0	0	0

Submission to other portals or systems

Question 9: the government proposes to allow businesses to comply by exception with the reporting requirements through reporting through a third-party scheme. Only schemes meeting regulatory standards would be designated by the Secretary of State for Health and Social Care. Do you agree or disagree with this proposal?

Of the 584 responses to this question:

• 191 agreed
• 274 disagreed
• 119 said they didn’t know

Table 10: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know
Individuals	118	201	90
Professionals	27	49	22
Regulatory body	1	0	0
Organisations	44	24	7
Academics	1	0	0

Question 10: do you currently report any payments to Disclosure UK, a voluntary scheme run by the Association of the British Pharmaceutical Industry (ABPI)?

Of the 537 responses to this question:

• 37 said yes
• 480 said no
• 20 said they didn’t know

Table 11: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	6	355	8
Professionals	8	77	7
Regulatory body	0	1	0
Organisations	23	46	5
Academics	0	1	0

Question 11: would you consider participating in or launching a similar scheme if this meant you or your members could be exempt from the legislative duty to report payments on your own website?

Of the 459 responses to this question:

• 61 said yes
• 213 said no
• 185 said they didn’t know

Table 12: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	27	157	135
Professionals	10	34	34
Regulatory body	0	0	0
Organisations	24	22	16
Academics	0	0	0

Information to be published and data protection

Question 12: the government proposes to require publication of a register of payments with entries containing the name of the recipient, the annual sum value of payments and benefits made, and a complete list of reasons for each payment and benefit. If the recipient is an individual, we would require businesses to publish their employer and professional registration number (if applicable and published by the professional body). What information do you think should be published?

There were 601 responses for this multiple-choice question.

Table 13: breakdown of results by answer

Answer	Number of responses
Name of the recipient	549
The annual sum value of payments and benefits	552
Complete list of reasons for each payment and benefit	522
If the recipient is an individual, their workplace and professional registration number (if applicable and published by the professional body)	495
None of the above	24
Don’t know	15

Question 13: the government proposes to require declarations to remain in the public domain for at least 3 years. Please choose your preferred timescale from the following options.

Of the 593 responses to this question:

• 36 said at least 1 year
• 118 said at least 3 years
• 345 said at least 5 years
• 11 said they didn’t know
• 83 responded ‘other’

Table 14: breakdown of responses by respondent category

Respondent category	At least 1 year	At least 3 years	At least 5 years	Don’t know	Other
Individuals	28	45	282	6	57
Professionals	2	28	48	4	16
Regulatory body	0	0	1	0	0
Organisations	6	45	14	1	8
Academics	0	0	0	0	2

There were 67 free text response for Question 13. All respondent groups tended to favour declarations remaining public for longer periods of time (such as 20 years or ‘career length’), with 31 respondents suggesting the information should be in the public domain indefinitely. A few respondents suggested alignment with existing requirements or legislation (such as the Medical Devices Regulations 2002 and the Limitation Act 1980) or that timescales be commensurate with a product’s development time or lifetime.

Enforcement

Question 14: should compliance with the requirements be monitored?

Of the 602 responses to this question:

• 569 said yes
• 20 said no
• 13 said they didn’t know

Table 15: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	413	4	5
Professionals	88	7	5
Regulatory body	1	0	0
Organisations	66	9	3
Academics	1	0	0

Question 15: how often should compliance with the requirements be monitored?

Of the 544 responses to this question:

• 92 said every 3 months
• 103 said every 6 months
• 285 said every 12 months
• 37 said every 24 months
• 27 said they didn’t know

Table 16: breakdown of responses by respondent category

Respondent category	Every 3 months	Every 6 months	Every 12 months	Every 24 months	Don’t know
Individuals	81	86	188	25	19
Professionals	9	8	57	6	4
Regulatory body	0	0	0	0	0
Organisations	2	9	39	6	4
Academics	0	0	1	0	0

There were 11 free text responses for question 15. Continuous or daily monitoring was suggested by 4 respondents. Other suggestions included ‘random’ monitoring or monitoring based on past or present compliance concerns.

Question 16: who should monitor compliance?

Of the 464 responses to this question:

• 57 said trade body
• 338 said government
• 53 said they didn’t know
• 16 responded ‘other’

Table 17: breakdown of responses by respondent category

Respondent category	Trade body	Government	Don’t know	Other
Individuals	35	250	40	15
Professionals	9	53	5	1
Regulatory body	0	0	0	0
Organisations	13	35	8	0
Academics	0	0	0	0

Some respondents selected a set answer and provided a free text suggestion.

There were 93 free text responses for question 16. A notable theme across respondent categories was preference for compliance monitoring by an ‘independent’ body, although there was significant variation in the proposed composition and/or affiliations (such as government and/or trade body) of any such body.

Question 17: how should suspected non-compliance be reported?

There were 556 responses for this multiple-choice question.

Table 18: breakdown of responses by answer

Answer	Number of responses
Contactable phone line	39
Email	47
Online platform	285
Through official checks only	70
Don’t know	58
Other	57

There were 57 free text responses for question 17. The option to have multiple (or all) of the above listed reporting routes available was suggested by a majority of respondents.

Question 18: where non-compliance is reported directly or flagged through the monitoring process, an investigation of compliance with the requirements could be triggered. Should all cases identified as potentially non-compliant be reviewed in full?

Of the 582 responses to this question:

• 467 said yes
• 30 said no
• 47 said they didn’t know
• 38 responded ‘other’

Table 19: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know	Other
Individuals	363	14	25	7
Professionals	71	8	13	5
Regulatory body	0	0	0	0
Organisations	33	8	9	25
Academics	0	0	0	1

There were 38 free text responses for question 18. Twenty of the respondents to this question (primarily from organisations) suggested a proportionate approach to investigations based on the level of non-compliance and/or risk, or that cases should be triaged.

Question 19: what triggers should be used to determine whether a case is fully investigated?

Of the 600 responses to this question:

• 221 said financial value of the case
• 168 said prior instances of non-compliance
• 80 said they didn’t know
• 131 responded ‘other’

Table 20: breakdown of responses by respondent category

Respondent category	Financial value of the case	Prior instances of non-compliance	Don’t know	Other
Individuals	174	117	54	76
Professionals	32	30	14	24
Regulatory body	0	0	0	0
Organisations	15	21	12	30
Academics	0	0	0	1

There were 123 free text responses for question 19. Individuals and professionals were more likely to suggest ‘all’ triggers, or triggers based on ‘both’ financial value and/or prior non-compliance, should be investigated. Respondents from organisations also cited financial value and prior non-compliance as relevant triggers, with 10 additionally suggesting that the threshold for any investigation be ‘risk-proportionate’ or on a ‘case-by-case’ basis.

Question 20: do you consider that financial penalties would be an effective and fair deterrent for non-compliance?

Of the 554 responses to this question:

• 305 said yes
• 136 said no
• 72 said they didn’t know
• 41 responded ‘other’

Table 21: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know	Other
Individuals	223	104	47	17
Professionals	49	24	13	8
Regulatory body	1	0	0	0
Organisations	31	8	12	16
Academics	1	0	0	0

Note that responses from individuals responding ‘yes’ includes 3 campaign emails.

There were 75 free text responses for question 20. A general theme across respondent categories was a scepticism that financial penalties in isolation would suffice. Other suggestions included additional penalties, such as:

• professional consequences
• criminal liabilities
• liability for directors and/or board
• ‘public reprimand’
• ‘enforcement mechanisms’
• non-compliance registers

Question 21: please share further comments or feedback relating to enforcement if you have any (maximum 500 words)

There were 287 respondents for this free text question.

Table 22: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	190
Professionals	53
Regulatory body	0
Organisations	42
Academics	2

This question received a diverse range of responses from across respondent categories with no specific suggestion supported by a majority of respondents.

Some common themes were identifiable. Thirty-five individuals were sceptical that financial penalties alone would act as a sufficient deterrent. Additionally, 33 individuals felt criminal charges and/or custodial sentences may be an appropriate penalty for non-compliance.

Thirty-two individuals and professionals suggested that any fines would need to be ‘significant’, or commensurate with the size of the company or financial benefit accrued from the payment to be effective.

Eighty-six respondents (from across categories) felt that alternative non-criminal penalties would be required instead of or in addition to financial penalties. These suggestions included:

• the loss of professional and product licences
• reputational consequences, such as publication of their details and non-compliance

Four respondents from organisations cautioned against a system that duplicates existing work or is burdensome or bureaucratic, with 3 respondents advocating for ‘flexibility’ in the reporting process. Three organisations also felt there should be procedures in place to manage ‘malicious’ reporting.

Payments out of scope

Minimum thresholds

Question 22: the government proposes to exempt businesses from reporting payments below £50 where the total annual value of payments does not exceed £500 for that recipient. What minimum value of payment do you think should be exempt from these regulations?

Of the 651 responses to this question:

• 182 said below £10 where the total annual value of payments does not exceed £100
• 193 said below £50 where the total annual value of payments does not exceed £500
• 85 said below £100 where the total annual value of payments does not exceed £1000
• 29 said they didn’t know
• 162 responded ‘other’

Table 23: breakdown of these results by respondent category

Respondent category	Below £10 where the total annual value of payments does not exceed £100	Below £50 where the total annual value of payments does not exceed £500	Below £100 where the total annual value of payments does not exceed £1000	Don’t know	Other
Individuals	145	146	56	17	112
Professionals	29	31	11	6	19
Regulatory body	0	0	0	0	0
Organisations	7	16	18	6	30
Academics	1	0	0	0	1

Note that responses from individuals responding ‘other’ includes 63 campaign emails.

There were 159 free text responses for question 22. A common theme across respondent groups was for no minimum threshold. Multiple respondents from organisations, however, suggested that payments of a certain category should be excluded to reduce administrative burden. Examples included:

• ‘sustenance’ or ’subsistence’ (such as coffee or a meal)
• training or educational items

Sixty-three campaign emails stated industry must log ‘all money given to the health sector’.

Research and development

Question 23: the government proposes to exempt businesses from reporting payments which may disclose commercially sensitive information under the condition that they publish their rationale for using the exemption and declare that they have applied the exemption. Which, if any, of the following options do you agree with?

Of the 593 responses to this question:

• 76 said they agree with the government proposal - that exemptions are permitted, the rationale for using the exemption should be given for every use and there should be a public declaration that the exemption has been applied
• 40 said they agree in part with the government proposal - exemptions should be permitted, and there should be a standard disclaimer published that the exemption has been applied to some payments
• 410 said they disagree with the government proposal - there should be no exemption, all payments should be reported
• 48 said a redacted version of the payments should be reported
• 19 said they didn’t know

Table 24: breakdown of responses by respondent category

Respondent category	Agree	Agree in part	Disagree	Redacted version	Don’t know
Individuals	48	19	331	17	5
Professionals	15	5	57	11	7
Regulatory body	0	0	0	0	1
Organisations	13	16	21	20	6
Academics	0	0	1	0	0

Question 24: the government proposes to exempt businesses from reporting payments and benefits made under contractual obligations where the healthcare provider organisation pays the business at fair market value, including discounts on prices that meet these criteria. Do you agree or disagree with this proposal?

Of the 586 responses to this question:

• 111 agreed
• 387 disagreed
• 88 said they didn’t know

Table 25: breakdown of responses by respondent category

Respondent category	Agree	Disagree	Don’t know
Individuals	55	310	50
Professionals	20	58	17
Regulatory body	0	0	1
Organisations	35	19	20
Academics	1	0	0

Question 25a - Do you think small and micro businesses should be exempt from the duty?

Question 25b - If you answered yes, please explain why you believe small and/or micro businesses should be exempt (maximum 250 words).

Question 25c - If you answered no, please explain why you believe small and/or micro businesses should not be exempt (maximum 250 words).

Of the 182 respondents to question 25a:

• 14 said yes, exclude small businesses (up to 50 employees)
• 14 said yes, exclude micro businesses (up to 10 employees)
• 138 said no, don’t exclude businesses based on size
• 16 said they didn’t know

Table 26: breakdown of responses by respondent category

Respondent category	Yes, exclude small businesses	Yes, exclude micro businesses	No, don’t exclude businesses based on size	Don’t know
Individuals	0	0	3	0
Professionals	11	9	76	4
Regulatory body	0	0	0	0
Organisations	3	5	58	12
Academics	0	0	1	0

There were 15 responses for question 25b. Ten responses from professionals and organisations felt that small and/or micro business should be exempt due to their relatively small market ‘influence’ and/or concerns about resourcing (such as staffing) necessary to comply with regulations.

There were 105 responses for question 25c. The primary concerns, common to all respondent categories, were that:

• all companies (regardless of size) should be treated equally
• the size of a company had no bearing on their potential payments and influence
• there was a risk of introducing potential ‘loopholes’ in the reporting system

Question 26: how much time and cost do you expect to incur in joining or setting up an alternative third-party reporting scheme?

Please provide an estimate by types of cost you expect, for example IT set-up (maximum 500 words).

There were 76 respondents for this free text question.

Table 27: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	0
Professionals	32
Regulatory body	0
Organisations	43
Academics	1

Nineteen professionals said they did not know, or responded ‘not applicable’, while 2 said costs would depend on the size of the operation. There was otherwise little agreement on this question.

While there was also variance among responses from organisations, a few themes emerged:

• 7 organisations said that the costs were unknown or difficult to quantify
• 14 organisations said costs would be ‘substantial’, ‘significant’, or greater than £2,000 to set up and provide yearly maintenance
• 8 organisations said costs would be minimal if third-party schemes such as Disclosure UK are considered a form of compliance, or if the new reporting format aligns with these

Question 27: how much (additional) time and cost do you expect to incur each year to declare payments, including to collect, review and publish the information?

Please provide an estimate.

There were 71 respondents for this free text question.

Table 28: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	0
Professionals	31
Regulatory body	0
Organisations	39
Academics	1

Twenty respondents said they did not know, or responded ‘not applicable’. Fourteen said time and cost would be minimal, or minimal if third-party schemes such as Disclosure UK are considered a form of compliance, or the new reporting format aligns with these. Seven professionals provided a range of answers from 1 hour to 5 working days or £200 to £250. Twelve respondents from organisations provided a range of answers, including:

• 2 hours
• 1 to 2 full-time equivalents
• £1,500 to £50,000

Question 28: if available, how many in-scope payments do you expect to make each year?

Please provide an estimate.

There were 63 respondents for this free text question.

Table 29: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	0
Professionals	26
Regulatory body	0
Organisations	37
Academics	0

Thirty-six respondents said they did not know, left a blank response, or responded ‘not applicable’. Six professionals and 2 organisations said they expected to make no payments. Seven respondents noted it was difficult to make an assessment as it would depend on clarification of the scope of payments. Three professionals offered specific figures from 100 to 1,000, and 7 organisations offered specific figures ranging from less than 10 to 8,000.

Question 29: are there any other issues or comments you would like to provide feedback on? (maximum 500 words)

There were 60 respondents for this free text question.

Table 30: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	0
Professionals	20
Regulatory body	0
Organisations	39
Academics	1

Professionals and academics generally welcomed payment disclosure, although 6 expressed reservations about voluntary reporting or declared preferences for a government-run or USA-equivalent system which mandates payments. Ten organisations asked for guidance to clarify how this policy would interact with General Data Protection Regulation (GDPR) and/or legitimate interest requirements, as well as clarity on:

• definitions (including ‘payments’ and ‘borderline substances’)
• avoiding duplication (such as the role of Disclosure UK)
• implementing a grace period or staggered rollout for any new requirements

Two respondents wished for clarity over how rules would apply to non-healthcare provider industry-employed healthcare professionals.

Realising the benefits of proposals

Question 30: thinking about the proposals outlined in this consultation, are there any other options for payment reporting which would achieve similar aims which the government should explore?

There were 385 responses for this multiple-choice question.

Table 31: breakdown of the number of responses by answer

Answer	Number of responses
Voluntary compliance with government-issued guidance	104
Voluntary publication of information currently required to be held by any trade association you are a member of	109
Other	172

Note that ‘other’ responses include 63 campaign emails.

There were 218 free text responses for question 30. There were reservations about voluntary reporting and/or support for mandatory or statutory payment reporting from:

• 64 out of 95 individuals
• 20 out of 31 professionals
• 9 out of 28 organisations

Eleven respondents suggested the introduction of a single public database of payments, with most specifying this be government-held.

Of the 63 campaign emails:

• all stated a preference for the introduction of a law (like the ‘Sunshine Act’ in the USA) that requires industry to declare all money given to the health sector
• 62 suggested one central, government-held public database free for the public to search
• 33 wished for such a database to be independent of industry

Question 31: please provide details of any current reporting systems in the UK which may result in duplication if this new duty is introduced.

This could be either voluntary or mandatory, industry or official reporting, excluding overseas requirements (maximum 500 words).

There were 81 respondents for this free text question.

Table 32: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	21
Professionals	17
Regulatory body	0
Organisations	43
Academics	0

Forty-one respondents made reference to the ABPI’s Disclosure UK system.

Other responses included:

• MedTech Europe database
• the Association of British HealthTech Industries (ABHI) voluntary scheme
• the European Federation of Pharmaceutical Industries and Associations (EFPIA) initiative
• Managing Conflicts of Interest in the NHS Guidance 2017

Question 32a: do you think the proposals will change patient relationships with their healthcare professionals?

Question 32b: if yes, how do you think these proposals would change patient relationships with healthcare providers?

Of the 602 responses to question 32a:

• 343 said yes
• 132 said no
• 127 said they didn’t know

Table 33: breakdown of responses by respondent category

Respondent	Yes	No	Don’t know
Individuals	259	80	83
Professionals	51	24	25
Regulatory body	1	0	0
Organisations	31	28	19
Academics	1	0	0

Of the 331 responses to question 32b:

• 313 thought it would improve the relationship
• 18 thought it would be detrimental to the relationship

Table 34: breakdown of responses by respondent category

Respondent category	I think it would improve the relationship	I think it would be detrimental to the relationship
Individuals	242	7
Professionals	40	9
Regulatory body	1	0
Organisations	29	2
Academics	1	0

Question 33: do you think these proposals would increase impartial decision-making from healthcare professionals and organisations?

Of the 586 responses to this question:

• 450 said yes
• 60 said no
• 76 said they didn’t know

Table 35: breakdown of these results by respondent category

Respondent category	Yes	No	Don’t know
Individuals	332	33	49
Professionals	72	11	13
Regulatory body	1	0	0
Organisations	44	16	14
Academics	1	0	0

Question 34: would you access and use the published information to make decisions on your healthcare?

Of the 573 responses to this question:

• 457 said yes
• 47 said no
• 69 said they didn’t know

Table 36: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	361	13	35
Professionals	71	14	13
Regulatory body	0	0	0
Organisations	24	20	21
Academics	1	0	0

Question 35: if this published information had been available to you in the past, would you have used it?

Of the 574 respondents to this question:

• 468 said yes
• 38 said no
• 68 said they didn’t know

Table 37: breakdown of responses by respondent category

Respondent category	Yes	No	Don’t know
Individuals	358	11	40
Professionals	77	11	10
Regulatory body	0	0	0
Organisations	32	16	18
Academics	1	0	0

Question 36: reflecting on the answers given to our proposals, please share any thoughts and further information to help us understand your views, especially where you disagree with proposals (maximum 250 words).

There were 221 respondents for this free text question.

Table 38: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	138
Professionals	33
Regulatory body	0
Organisations	48
Academics	2

This free-text question received a diverse range of responses from across respondent categories with no specific suggestion supported by the majority of respondents.

Despite this, some common themes were identified:

• 57 individuals and professionals provided feedback that they felt there was payment-related bias in healthcare
• 38 welcomed actions being taken to increase payment transparency
• 29 individuals suggested they had lost trust in healthcare, industry or regulators

Respondents from organisations requested clarification on the consultation’s proposals. Fourteen raised concerns about the time between any new legislation and enforcement taking effect, suggesting it would be challenging for industry to comply with a period of 6 months or less.

Academics fed back that the scope of payment reporting should be wider, to include groups such as researchers. They also stated preferences for:

• a central national database
• a statutory scheme
• subsequent work by government to ban all payments to healthcare outright

Feedback

Respondents were asked to provide a satisfaction rating to reflect their experiences of the survey process.

Table 39: breakdown of the number of responses by answer

Answer	Number of responses
Very satisfied	57
Satisfied	402
Dissatisfied	67
Very dissatisfied	18

Respondents were then asked to provide freeform feedback on the consultation process. 153 responses were received.

Table 40: breakdown of the number of responses by respondent category

Respondent category	Number of responses
Individuals	104
Professionals	26
Regulatory body	0
Organisations	23
Academics	0

Sixty-six individuals suggested that the consultation should have been publicised more widely, suggesting such consultations should be advertised through:

• social media
• news channels
• healthcare settings

Twenty-three respondents (across categories) shared their thoughts on the design and wording of the survey questions. Some felt the questions were ‘confusing’ or not relevant to individuals, while others asked for more opportunities to provide alternative responses (such as ‘not applicable’) or free text options or comments for all survey questions. Three organisations felt more detailed proposals would have been helpful.

Of the 65 campaign email responses, 61 provided feedback stating that they found the consultation survey ‘very confusing’ and felt unable to provide their views in this format.

We are grateful for all feedback provided by respondents.