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transparency obligations overview

Last reviewed: January 2024 | Important Notes
PHARMACEUTICAL

Report Due Date

Within 6 months after the end of the relevant Reporting Period

“The first reporting period covers the 2021 calendar year and the first reports will be due at the end of June 2022.”

Authority

Medicines New Zealand and New Zealand Medical Association (NZMA)

Who Must Report

Members of Medicines New Zealand and New Zealand Medical Association (NZMA)

Covered Recipients

HCPs and HCOs

Pharmaceutical Companies

What is reported:

  • Event registration fees
  • Travel & accommodation costs
  • Fees for service & consultancy

How to Report

“There are no de minimus threshold levels for reporting of Transfers of Value. This means that all payments to Healthcare Professionals must be disclosed in the report.

The contents of the Report must include:

  1. Name of Healthcare Professional or Healthcare Organisation
  2. The Healthcare Professional’s address and geographic location

iii. The dollar level of transfers of value given aligned to the activity categories of payments detailed in sections 3.1.1-3.1.3. A template for the Report has been included in Schedule 2, which can be utilized by a Member Company should it not have an existing template that would capture the above information highlighted in Section 3.1.”

Resources

https://www.medicinesnz.co.nz/our-industry/transparency-guidelines

https://www.medicinesnz.co.nz/fileadmin/user_upload/Medicines_New_Zealand_Transparency_Guidelines__15_Oct_2020_.pdf 

 

Important notes:

  • This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
  • Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information provided reflects the most recent changes and is still applicable.
  • Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding – in most cases – suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. In case it is based on codes of conduct, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of the association that follows that code.
  • Including a jurisdiction in the Legislative Watch does not guarantee that jurisdiction is available for reporting via the MediSpend Transparency Reporting Solution.
  • Reporting date normally means the date the transfers of value need to be published. The deadline for e.g. submission/sending the complete information to the authority could be before that date, for example to give HCPs and/or HCOs and/or the authority/association who publishes the information, the possibility to check the data the pharmaceutical companies/medical device companies are going to disclose.
  • The information does not take into consideration (unless explicitly mentioned):
    • Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
    • Transparency related to patient organizations (unless the patient organization is considered an HCO)


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