Frequently asked questions

Transparency Code

The following interpretation means individual interpretation by individual AIPM member companies and based on information sharing. This is only a recommendation with no legally binding effect.

The company with the profile of providing professional services owned by a doctor is falling under the definition of HCP or HCO?

HCO. See the definition of HCO in local Transparency Code: Any healthcare service provider within the meaning of the act on healthcare or any organization through which Transfers of Value are directly or indirectly made to HCPs.

What is the meaning of direct and indirect ToV to HCPs?

Direct, when the HCP is receiving it (e.g. honorarium). Indirect, when HCP is the beneficiary, but ToV is not directly made to them (e.g. registration fee). In the case of event organizer the Medical Association shall be disclosed as the beneficiary of ToV. In this case third party Agreement might be concluded among the company, Medical Association and event organiser.

Is there a Disclosure Consent needed from HCOs?

Yes. HCO shall consent to the disclosure of the content of the contract, business confidential information.

How should the ’Full name’ appear in the report?

As the official name of the party, or as it appears in the official registry ( and on the doctor’s seal. In the case of HCO: the registered company name.

In case the event is held in December 2014, but the payment occurs in 2015, should this be included in disclosure?

The member company shall decide on the process of disclosure. See also EFPIA Q&A Batch 3 dated 19.12.2014, Question 2.01 – 1)

Should Product donation to hospitals be disclosed?

Yes. How can be the price indicated? In the case of reimbursed medicine: reimbursed price, not reimbursed medicine: list price.

If companies provide transfer of value to a HCO through a congress organizer agency, how the consent can be obtained?

This is up to the legal solution the company wishes to use. There are a couple of possibilities; one of them is to sign a contract by all 3 parties (i.e. congress organizer, company and HCO) where HCO gives its consent to disclosure of business confidential information.

What currency need to be used when a benefit is disclosed?

No common guideline, this need to be defined in methodology note by the companies.

Does the reporting need to be done in the name of the individual legal entities or the company group?

No common guideline, this need to be defined in methodology note by the companies.