Frustrate and Bewilder: F&B at Medical Meetings
The term F&B in the meetings industry refers to food and beverage. For medical meetings specifically, it could also stand for “frustrate and bewilder.” Since the passage of the Physician Payments Sunshine Act in 2010 (renamed the National Physician Payment Transparency Program: Open Payments in 2013), reporting transparency of spend in the category of “food and beverage – meals” has not gotten any easier.
In fact, with 88 countries now having some type of healthcare spend reporting, it has become even more complicated. Every country has a different set of rules, and every manufacturer (pharmaceutical, medical device, biopharma, biologic) has their own set of limits and meal caps. Many regulations call for “reasonable” F&B limits, but there is no standard definition for what exactly qualifies as “reasonable.” In fact, there is no consistency, standardization, or predictability for anything related to food and beverage across medical meetings.
Planning HCP Meals: Four Critical Elements
Before I explore the details (or lack thereof) of reporting and compliance guidelines, it is important to understand the four elements of planning meals for HCP meetings: discovery, menu planning, budgeting, and compliance.
Step 1: Discovery
Information to gather during the discovery process includes the following:
- What company is hosting the meeting and where are they headquartered? The pricing of all meals is now based on the rules and regulations of the host country, not the meeting country or the HCP origin countries. If the host’s country does not have set restrictions, like the US (more on that later), defer to the company’s internal policies. Please note, however, that transfer of value still needs to be reported according to the HCP’s countries of origin.
- What are the host company’s internal guidelines? These always need to be followed in addition to any compliance rules of their home country.
- How many HCPs are expected to attend? While some meetings don’t need this finalized until closer to the event date, this information is crucial for pharma and medical meetings as it affects meal caps and menus.
Step 2: Menu Planning
Some venues have pre-determined HCP menus, which makes planning simple. Others may require a sample menu be created to ensure the venue is capable of meeting the food and beverage limits.
Some food and beverage trends to keep in mind when planning your menu include:
- Attention to nutrition and wellness with features such as juice bars.
- Local sourcing, including farm-to-table meals.
- Covered cuisine or boxed to-go meals.
- Outdoor dining, including mobile food trucks for greater variety.
- Shorter receptions, which in turn require less food and beverage.
Step 3: F&B Budgeting
It’s no secret that HCP meal caps are stringent, and the challenge is compounded by the fact that already sky-high F&B costs will continue to climb. This is due to a variety of factors including increased production prices, environmental effects on imports and exports, and marked rises in attendees’ special dietary requests.
Ways to stretch the budget and save on F&B costs include the following:
- Hold meals or full events in restaurants instead of hotels. Many restaurants now have established medical meeting menu options which range in price, providing flexibility with the budget while still ensuring quality meals.
- Utilize unique venues. Because food and beverage are not their main source of revenue, they can be negotiated more easily and may not have as high of mark-ups.
- If a meal must be held in a hotel or larger event space, consider food stuttering—asking what is being served to other groups and serving the same or similar meals.
- If possible, work directly with the chef to craft the menu. No one knows how to save money on meals better than the chef!
- Design inclusive menus such as gluten-free or vegetarian to accommodate common allergies and dietary restrictions. This eliminates the added cost of individually accommodating common requests.
- If serving prepackaged items, include in the hotel or venue contract to return any uneaten items and only pay for what was taken.
Step 4: Compliance
In addition to budget, compliance rules play a significant role in determining the final menu, so it is best practice to be aware of both budget, and applicable rules & regulations when recommending or considering menu choices. As a reminder, the meal caps must be compliant with the host country, and transfer-of-value reporting is determined by HCP’s countries of origin.
Reporting Requirements in the US and Europe
Congress passed the Open Payments program as part of the Affordable Care Act to shed light on the financial relationships between drug and medical device manufacturers and doctors. The program requires detailed reporting on a public website of every “transfer of value” to a doctor or other HCP who attends a meeting paid for by the pharma company. The end goal was to enable patients to make more informed decisions when choosing healthcare professionals (HCPs) and deciding on treatments. The law is also meant to deter inappropriate financial relationships that might lead to increased healthcare costs. One of the Nature of Payment categories that must be reported in the US is food and beverage.
Interestingly, the European equivalent to Open Payments, the Disclosure Code led by the European Federation of Pharmaceutical Industries and Associations (EFPIA), does not require any food and beverage reporting of transfer of value from a manufacturer to an HCP for the simple reason that they did not think they could handle the administration of calculating these expenses. At the national level, however, some European countries, such as Austria, Belgium, and France, now require the report of transfer of value on F&B.
The Impact of PhRMA and Open Payments
In addition to the provision of Open Payments, pharmaceutical companies and medical meeting planners also defer to ethical codes and guidelines provided by Pharmaceutical Research and Manufacturers of America (PhRMA). While longstanding and widely accepted in the industry, PhRMA’s guidelines are actually quite vague. Concerns about optics have forced pharmaceutical companies to set strict, conservative limits on the amount of money they can spend on hotel rooms, food and beverage, and other costs such as transportation. Given the preexisting and much-feared PhRMA guidelines, Open Payments then led to even more draconian limitations on spending.
In some instances, the restrictions are about what can be served, not just the cost of what to serve. For example, in August 2022, PhRMA made revisions to include the controversial guideline specifying that “companies should not pay for or provide alcohol in connection with speaker programs.” This caused some pushback from HCPs who felt that they should be able to make their own decisions about beverages at programs.
Incredibly, however, there is no formal set of spending guidelines. Neither PhRMA nor Open Payments dictate any specific restrictions or cite any numbers. In effect, acute paranoia about optics has motivated pharma companies to set increasingly conservative spending restrictions of their own—with little commonality among them except that expenditures have been reduced. Each company creates their own meal caps based on an abstract formula that includes PhRMA’s broad ethical guidelines, the specific reporting requirements of Open Payments, and sensitivity to optics.
The Future of HCP Food and Beverage
Unless there are a global set of standards that are adapted and shared with all countries, food and beverage reporting will not get any easier any time soon. While I suspect F&B will always be frustrating and bewildering, working with knowledgeable professionals who know the ins and outs of HCP compliance and reporting will make the process smoother.
Interested in learning more? Contact us.
Contributor
Pat Schaumann, CMP, CSEP, DMCP, HMCC
Principal Consultant, Life Sciences
Meetings & Incentives Worldwide, Inc.