The Association of the British Pharmaceutical Industry (ABPI) Disclosure United Kingdom recently warned the pharma industry that the data quality of transparency disclosure submissions did not meet the required standard. Submitting flawed data poses significant risks, not least breaching the ABPI code.

As media scrutiny increased in 2023, the UK government’s recent public consultation on disclosure legislation is expected to intensify that scrutiny even further. Therefore, it is critical that companies implement measures to improve data quality or risk negative reputational impact with both HCP/HCOs and the public.

Recommended actions to avoid submission of flawed data include:

• Implement or strengthen SOPs to ensure data accuracy, ensuring procedures for disclosure management are robust and will stand up to scrutiny, including the implementation of in-house pre-disclosure processes prior to data submission.
• Align non-UK affiliates/subsidiaries to ensure inclusion of cross-border values to UK recipients.
• Make full use of the pharma review checking period, managed via the disclosure portal, to thoroughly review data before it is released to the named HCP and HCOs.
• Ensure your company is best placed to manage potential data amendments by ensuring staff are fully trained on the use of the disclosure portal.

Compliance and disclosure resources:

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