Adhering to regulatory or statutory requirements is important in attaining rational drug use. A DTC can ensure proper enforcement of regulations within the environment of the health facility.
7.4.1 Supporting national regulations
• Drug registration, when enforced properly, will keep ineffective, poor-quality and dangerous medicines off the market and out of the country. Monitoring and enforcing the registration system is important, as otherwise large numbers of unregistered medicines may reach the public and private health-care systems. The DTC should ensure that only registered drugs are used.
• Professional licensing of health-care professionals restricts membership of these professions to individuals who are competent and have the necessary training and experience. Licensing can be extended to include level-of-use prescribing, where restrictions are placed on the type of drugs that providers can prescribe depending on their training and experience. The DTC should ensure that only licensed health-care professionals are employed and that their duties comply with national regulations concerning level-of-use prescribing.
7.4.2 Hospital policy on pharmaceutical promotion
Pharmaceutical promotion influences providers at the level of drug selection for the formulary and the choice of drug for individual patients. For many prescribers, drug company representatives are the primary source of information on new medicines. However, their information is often biased since they are primarily salespeople interested in promoting the drugs sold by their companies. Often providers do not realize how they are influenced by promotional materials and activities. Thus providers must be sensitized as to how pharmaceutical promotion can affect their choice of medicines, and trained to analyse the content of promotional materials. Regulating interaction with drug representatives helps the DTC to promote the rational use of medicines and ensure, as far as possible, that the content of materials and information reaching prescribers will be unbiased.
The WHO (1988a) Ethical criteria for medicinal drug promotion can serve as a basis for developing measures and guidelines on drug promotion. This document states that ‘All promotion-making claims concerning medicinal drugs should be reliable, accurate, truthful, informative, balanced, up-to-date, capable of substantiation and in good taste.’
Regulating drug representatives may be difficult in larger hospitals, or where doctors have active private practices. A DTC may choose to ban representatives entirely, which can be counter-productive as they then approach doctors outside the hospital. One option used in some countries is that of equal time presentations. In this approach representatives are required to submit their materials in advance. The hospital pharmacist or a clinical pharmacologist (if there is one) actively reviews the materials. A meeting is then arranged at which the representative is invited to present his/her information to all doctors, followed by equal time for the pharmacist (or clinical pharmacologist) to comment on the materials presented. Then the meeting can be opened for questions and discussion. By debating the merits of a new medicine it is possible for prescribers to gain a balanced perspective on that medicine.
Promotional activities may be directed at consumers as well as prescribers. Such promotion may create inappropriate patient demand. A DTC cannot prevent such promotional activities occurring in society at large, but it can ban them in the hospital or facilities under its jurisdiction. For example, a DTC can prevent the display of inappropriate posters, advertising medicines and aimed at consumers, in the hospital or health-care facility.