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Medical Device Compliance Congress: Global Device Codes Roundtable - Australia Anne Trimmer. Agenda. Background to 3 rd Edition Advertising and claims Dealings with healthcare professionals Company representatives Complaints Code monitoring. Background to 3 rd Edition.
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Medical Device Compliance Congress: Global Device Codes Roundtable - Australia Anne Trimmer
Agenda • Background to 3rd Edition • Advertising and claims • Dealings with healthcare professionals • Company representatives • Complaints • Code monitoring
Background to 3rd Edition • Initial implementation 2 years ago • First complaint and appeal • Language issues • Increased compliance focus globally • Inconsistencies with AdvaMed Code and many member internal codes
Headline news • Law on ties between surgeons, device makers insufficient • Kickback claims being taken 'very seriously' • Hip bones and hip pockets • Group calls for ethical conduct plan for Australian device makers
Advertising – 3 tiers • Regulation • Therapeutic Goods Act and Regulations, Trade Practices Act • Co-Regulation • Therapeutic Goods Advertising Code • Self-regulation • Company codes • Voluntary industry codes • MTAA/MIANZ Code
Dealings with healthcare practitioners • Definitions • Healthcare Practitioner • Other Professional • Member-sponsored training and education • Third party educational conferences • Member-sponsored symposia • Hospitality
Dealings with healthcare practitioners • Hospitality and gifts • Consultancy arrangements • Donations and philanthropic gifts • Competitions for healthcare practitioners • Market research
Company representatives • Requirement for ethical conduct • Not compromise professional independence of healthcare practitioner • Compliance with institutional standards, codes and laws • Requirement for every representative within 6 months and 3 year refresher • Training must be approved by MTAA
Code complaints • Strengthened committee structure for complaints and appeals • Panel of 12 and independent chair: • Healthcare practitioners • Institutions • Consumer representatives • Industry
Code complaints • Complaints from industry and non-industry • Industry must first raise with other member • Complaints committee may call on expert assistance • Breaches range from minor to serial • Maximum fine of $75,000 • Power to notify regulator
Code monitoring • In addition to complaints process • Proactive monitoring – may call for material • Independent chair • May call for material or outline of activity