Transparency

 

On 1 January 2012, the CGR implemented new rules on the disclosure of financial relations. These rules require that arrangements be made for the disclosure of service and sponsorship relationships agreed between pharmaceuticals companies and healthcare professionals, partnerships of healthcare professionals and institutions which employ healthcare professionals. Disclosure is compulsory if the healthcare professional, partnership or institution in question receives more than € 500 (in money or in kind) from a pharmaceutical company in any calendar year.

The rules stipulate that disclosure is to take place each year following the year-end by means of a single centrally held transparency register. In principle, the pharmaceutical companies are responsible for reporting financial relationships to the transparency register. If a healthcare professional has entered into a financial relationship with a pharmaceutical company based abroad, the obligation to register it lies with the healthcare professional. Financial relationships effectuated in 2012 and which exceed the € 500 limit in total must be entered in the central register at the start of 2013.

Disclosure takes place in a central transparency register, set up in collaboration with the Ministry of Health, Welfare and Sport. The management of the register is entrusted to an independent foundation (Stichting Transparantieregister Zorg)

The public may consult the transparency register through the internet. The data are searchable by the name of the recipient, i.e. the name of the healthcare professional, partnership or institution. Entering the name will produce a summary of the reported financial relationships which the party in question has had with pharmaceutical companies.

For the sake of clarity of registration and accurate linking of data, a reliable database is crucial. The transparency register is entitled to use the Individual Healthcare Professions (BIG) register of the government, which provides a guarantee of accuracy in registering personal data and compiling the central register.

The register has the following reporting structure:

1. The name of the healthcare professional, partnership or institution concerned;
2. The name of the pharmaceutical company concerned;
3. The nature of the financial relationship;
4. The amount;
5. The year to which the relationship relates.

Name of the recipient: in order to be able to “match” the names of healthcare professionals, a unique number must be used. As indicated above, the BIG number is used for healthcare professionals. For partnerships and institutions (legal persons), their registration numbers with the Chamber of Commerce are used.

Name of the pharmaceutical company: the name of the pharmaceutical company which registers as a sponsor. If a professional has entered into a financial relationship with a pharmaceutical company abroad and reports the relationship him/herself, the company name submitted by him/her will be entered.

Nature of the relationship: the reporting party will be asked to classify the financial relationship in question according to one of the following categories:

Consultancy services
Advisory board services
Services for non-interventional research outside the scope of the Dutch law on medical research in humans
Other services
Sponsorship of meeting
Other sponsorship


The amount: Amounts are submitted in whole euros.  In the case of service provision by a healthcare professional, only the fee (excluding VAT and expenses) is to be registered. In case of sponsorship agreements, the full sponsorship amount is to be submitted. If as part of an agreement with a partnership or institution, personal services are rendered by a healthcare professional, this relationship must be registered separately, stating the fee received for these services. In such a case, therefore, certain sums of money must be submitted twice: the total contract value in the name of the partnership or institution and the fee for the personal service provision in the name of the healthcare professional concerned.

The transparency rules apply not only to monetary reimbursements but also to reimbursements in kind. Reimbursements in kind must be submitted at their equivalent monetary market value.

The year: 2012 submissions relate to payments made in 2012 and/or payments for which the service or sponsored activity was performed in 2012. If the service was not completed in 2012 or if the sponsorship continues after 2012, these relationships are to be reported in 2013. Reporting takes place after completion of the service and/or sponsorship.