Jean-Christophe Bélisle-Pipon calls attention to issues of accessibility and transparency related to the collection and sale of physician prescribing data by data solution companies.
QuintilesIMS is a data solution company that provides services to the pharmaceutical industry. In 2002, the company was authorized by the Commission d’accès à l’information du Québec to receive and make use of personal information held by Québec pharmacies about physician prescribing practices, provided that: 1) specific professional acts were not linked to specific professionals; 2) physicians could refuse to have their information used; and 3) use of the information was restricted to reaching out, informing and training physicians. Data related to physician prescribing practices is sold by Québec pharmacies to QuintilesIMS. In turn, QuintilesIMS collects, collates this data and sells it to pharmaceutical companies for marketing purposes.
Recently, information related to QuintilesIMS business practices was leaked to the media.
Allegations have been made suggesting that data detailing the prescribing practices of 7,000 Québec physicians (including identifying information) have been disclosed to pharmaceutical companies. If proven true, this would represent an unauthorized practice, that contravenes the Act respecting the protection of personal information in the private sector. The issue at stake in the allegations is not the disclosure to companies, but rather, the disclosure of identifying information.
Physician prescribing data must be clustered in groups of 30 that have similar prescribing profiles. Thus, it is impossible in Canada (contrary to the US) to have access to individual physician prescribing profiles. In Québec, physicians can opt out of this data collection, and those who allow their information to be used, freely have access to their own prescribing profile. However, many physicians do not even know that their prescribing habits are being tracked.
Why does the information allegedly disclosed by QuintilesIMS matter? It is the only comprehensive data that industry can access about physicians’ prescribing habits. Physicians are only indirectly involved in drugs’ sales, insofar as they prescribe drugs to patients. This prescription is used by QuintilesIMS to trace back the ‘sale’ of a drug to a physician. Physicians are the gatekeepers of pharmaceuticals, so they represent the most important targets of pharmaceutical marketing (at least in terms of marketing expenses).
I have first-hand experience with physician prescribing data. I worked in a business intelligence department and would use QuintilesIMS’ clustered data to forecast pharmaceutical trends and make sales projections. I ranked physicians according to a whole set of metrics and stratified them as heavy/low prescribers and determined which company’s drug they were more likely to prescribe. I would assess whether physicians were early-adopters (eager to prescribe newest drugs) or traditionalists. Virtually all pharmaceutical sales plans and marketing strategies are based on QuintilesIMS data.
Accessing this data is very expensive, typically costing several thousand (or hundreds of thousands) dollars, so typically, only larger companies can afford to buy datasets. It is very difficult for researchers or public agencies to pay to access this data. Therefore, pharmaceutical companies have an informational advantage about prescribing behaviours over regulators, researchers, and patients’ advocates.
The current allegations against QuintilesIMS are being dealt with by the investigation services of the Commission. The result of their inquiry will not be known for several months (or years). During that period, it is unclear whether QuintilesIMS will continue to receive the data from pharmacies and how long it will take for the Commission’s investigation report to be publicly available.
Nevertheless, public scrutiny of this potential misconduct and unauthorized use of data draws attention to important questions about access to physicians’ data. It may be time to revise the authorization granted by the Commission in 2002, and to renegotiate its terms. First, since we are in an era of access to information and transparency, we should enshrine a privileged access clause for citizens and researchers, making clearer that data should be freely accessible for non-commercial and prosocial utilization. This access should not be left to the discretion of QuintilesIMS, as is currently the case. Arguably, the authorization was granted to suit the commercial interests of QuintilesIMS and it is now time for a change. For reasons of transparency and access to the data, I suggest that we establish a data collection and sharing regime that fosters research and supports transparency in pharmaceutical trend surveillance. Second, I suggest that we should implement an opt-in consent system rather than an opt-out system for physicians. Much more should be done to inform physicians about prescribing data collection and they should be able to decide whether they want their data to be disclosed and whether they want their data to be used for public research and/or commercial purposes.
The recent allegations against QuintilesIMS present a window of opportunity to discuss the ethical collection and use of physician prescribing data. This topic is often overlooked, but is of high-importance to the public. Going forward, physician prescribing data should be publicly accessible and transparent, in order to help promote the common good.
Jean-Christophe Bélisle-Pipon is a PhD Candidate in the Bioethics Program at the School of Public Health of the Université de Montréal. @BelislePipon