Fair Market Value: Perspectives from Annual Conference 2023

Are your ‘incentive’ payments compromising your data?

Primary market research wouldn’t be possible if we didn’t collaborate with the experts in the field, be that healthcare professionals (HCPs) or patients and their families or carers. Their involvement necessitates time that would otherwise be spent elsewhere and when we take our experts away from their daily lives, we need to value and respect their time, which we traditionally do via ‘incentive payments’.

The BHBIA annual conference 2023 addressed the issues of value, including ethics and responsibility for setting payment levels, societal and economic pressures and the importance of clear communication to ensure robust research outcomes.

Legitimised 'incentives'

As a practice, Fair Market Value (FMV) is not new. It is a payment that legitimises the interaction between the pharmaceutical company and the respondent and is a recognised means of recognising the expertise and time offered by participants.i, ii, iii, iv, v From the pharmaceutical company perspective FMV sets a considered rate for payments made to HCPs, patients and their families or carers in return for their expert advice, provision of stories and involvement in market research. As an industry, pharma relies on this input to achieve critical insights into their business. Everything from clinical trial development through involvement in business insights to advice on advertising can be covered by FMV rates established by individual companies to those providing their expertise.

Current Guidance

The ABPI and EFPIA provide guidance on working with third parties as they recognise the vital insight they bring to the industry. iii, iv, v Both organisations provide information on reporting transfer of value in relation to payments made by pharmaceutical companies to HCPs and the public, however neither organisation provides values for companies to work within, recommending instead ‘honesty and transparency’.iii, v  This leaves pharmaceutical companies to set their own payment levels, which they keep confidential. There is no single approach to level setting, with companies often using similar payment ranges to cover complex audiences. Pharmaceutical company standards often fall short when considering the complexities involved in market research.i The BHBIA stepped in in 2022 with ‘Guidelines for Incentive Payments for Market Research’, taking the discussion one step further, encouraging discussion between the pharma company and agencies involved in market research to ensure rates offered balance the participant characteristics, the fieldwork requirements and the environment within which the fieldwork is taking place.i

Oversight

Any payments made by a pharmaceutical company usually require compliance or medical team oversight to avoid any potential for classification as an inducement. Feedback from BHBIA conference attendees, reflecting experience from both in-house and agency, indicates that compliance teams are rarely involved in budget discussions for market research which could be compromising projects – more on that later. Any guidance on FMV values reflecting the complex healthcare environment would therefore be a welcome structure to use from a compliance perspective, as it enables pharma companies to make payments in line with a fair standard so that, in theory, one company is not paying more than another to the same group of experts.

The trend of declining participation

Over the past few years, BHBIA has noted a shift in attitude related to FMV, coinciding with budgets being squeezed and heightened sensitivity to external scrutiny. The market research budget increasingly feels the pinch. This squeeze on budgets, alongside external issues, including Covid-19, makes fieldwork difficult and heightens the need for clear communication and openness around ‘incentives’ to respondents.i

BHBIA’s own market research highlighted that since approximately 2015 recruitment rates have been steadily declining.vii In our post-Covid world, where health systems are under pressure and patients are navigating new pathways of care, we need to recognise the value their lived experience provides to market research. To facilitate this, the true value of participants’ worth needs to be appreciated. Anecdotal feedback suggests that variability in payments between companies can lead to participants cherry-picking the companies and projects they wish to be involved with. The possible conclusion here being participants decline market research with lower paying companies, while higher paying companies reap the benefits of additional involvement and more robust market research.

Compounding this issue, remunerating participation only through cash paid by bank transfer and the ending of voucher payment, which is a preferred practice by some companies, has led to a further reticence in HCP, patient and carer participation: “Many patients take part in [market] research altruistically, and they appreciated receiving vouchers – they were able to pass these on to children and grandchildren. Some now don’t feel as comfortable receiving money for their time.”

Rate variability, economics and specialists

The BHBIA notes that rates for FMV, along with the team setting the rates, vary by company. The team involved is often one step removed from the market research. These factors, coupled with the demand placed upon respondents to take part, can result in rates rarely reflecting the value that should be granted to participants.i This exacerbates the issue of declining response rates.

Feedback from BHBIA members suggested that rates have stayed static for the past few years, contrary to inflation and the pressure on HCPs as their workloads have increased with pressures on the NHS in the UK and other health systems. This pressure isn’t exclusive to HCPs, as the current economic pressures affect patients and their families or carers too. Declining response rates have a knock-on impact to project times and cost. The longer it takes to fulfil a brief with the required number of respondents, the higher the cost to the purchasing company.

Specialist HCPs demand a higher value fee than non-specialists, given their higher depth of knowledge and expertise and the smaller numbers of individuals able to respond to specific briefs. This is noted by many pharmaceutical companies, with FMV tables reflecting a higher rate for specialists versus generalists. However, feedback to BHBIA suggests that external pressures including rising inflation and pressures within health systems, lower rates can and do have a negative impact on market research.

A recent survey by EPHMRA of eight pharmaceutical companies in five European markets stratified levels of payment across participant groups which could potentially aid in discussions for agreeing fair rates for market research.viii


Case Studies:
A pharmaceutical company commissioned an agency to run a research project with a cohort of specialist healthcare professionals. The company set the payment values and was not prepared to manoeuvre on these.


When the data was analysed, the story was confusing and didn’t appear to give accurate insight. It became apparent on checking the respondents that the lower payment values on offer had elicited many more junior HCPs responding to the research. The less experienced HCPs did not have the necessary clinical experience and had not seen enough of the specific patient cohort to be able to answer questions accurately.
The entire study resulted in questionable data. The solution would be to pay the value required of specialists and representative of today’s economic situation.

A further case relayed focused on changing parameters mid-way through a project. While reworking questionnaires and cohorts may seem inconsequential on paper, in reality, it requires a ‘back to the drawing board’ approach in terms of the HCP or patient specialists needed to provide robust data sets. The time it takes to source specific participant cohorts and importantly the value of their time also necessitates budget negotiation. The original budget, especially the FMV rates agreed, requires a bottom-up rework with the commissioning company. If clear and open lines of communication are not set up from the outset, this could compromise the fieldwork.

A further point to consider is whether cross-border recruitment and sub-contracting may be necessary. In this case, communication with the third party regarding their recommended rates would be advantageous, taking into account differing exchange rates. Something as simple as this can push rates lower than agreed, leading to ill-feeling among participants.


The importance of valuing specialist experts

Returning to our expert HCPs and patients, the specialists in their field, we must recognise that our customers and end users of our products are the experts in therapy areas.

For example, cardiologists are experts in cardiology; patients and their families living with HIV are the experts in HIV. Without this expert input and opinion, pharma operates in a vacuum. Often, we need to conduct market research with specialist experts who have the deep knowledge, skill and expertise in their therapy area, and of which there are usually only a few individuals in each speciality to draw upon. This can mean they command higher rates for their time because they will be called upon more often to provide research input, from interviews through to advisory panels or research groups. Considerations for valuing patients in market research include acknowledging their specific situation, from the severity of their disease, plus the demands of treatment and limitations placed on their life, all the way through to their life expectancy, All these factors should influence the value we place on their time.

When it comes to addressing availability of respondents and therefore FMV payments for research, there are multiple variables to take into consideration from length of interview (LOI) to accessibility of materials, for example the need to download an app to complete the research, the demand on time for the interview, for example, does it need to be conducted at a specific time (and in which time zone), or is it something a participant can do at their leisure, and as mentioned earlier payment methods the participant is restricted to.i

Communication is King

Through BHBIA research and interviews, the key to resolving the tension points in FMV points to a need for improved communication between agencies, third parties and the commissioning company.

Feedback to the BHBIA suggests that the market research community has potentially made things more difficult when discussing remuneration for participants by naming such payments as ‘incentives’. The terms honoraria, remuneration or fee would perhaps be less incendiary nomenclature for the sensitive and highly regulated pharmaceutical industry. Translation, when research is taking place across markets, further complicates payments with the use of ‘incentive’ potentially being taken literally.

At this time, a discussion around re-assessing FMV rates would be welcome. Many FMV pharmaceutical company guidelines have taken many years to be drawn up and confirmed, and in that time, inflation has increased, and the healthcare landscape has changed, meaning the rates are out of date by the time the process is published.

Anecdotal evidence suggests that the important communication at the time of set up of a project is lacking and compliance or medical need to be involved in discussions and be presented with the rationale for expert stratification and their required fee level, metrics required for robust data sets, implications for recruitment difficulties leading to potential delays with recruitment in terms of overall budget and metrics.

Implementing Good Practice

Returning to the initial question, do incentive payments compromise research? They can do, for various reasons including the potential for low payments resulting in mismatched respondents and subsequent poor-quality data.

Following best practice can help and the good news is that the BHBIA published guidelines with the aim of highlighting the specifics that should be considered when defining incentive payments for participants. The guidelines include both a respondent characteristic framework and a fieldwork checklist. Taken alongside tabulated payment data, this can aid in setting fair rates specific to the participants involved, representing their expertise (HCPs), specific condition (patients) plus a number of factors relevant to the fieldwork required.iviii  

These guidelines can be used as the starting point for discussions between all parties, at the time of commissioning projects.

References:

i Fair Market Value | BHBIA. (2023). Bhbia.org.uk. https://www.bhbia.org.uk/guidelines-and-legislation/fair-market-value

ii ABPI Code of Practice for the Pharmaceutical Industry. (n.d.). https://www.pmcpa.org.uk/media/3406/2021-abpi-code-of-practice.pdf

iii ‌ABPI. (2021). Payment. Abpi.org.uk. https://www.abpi.org.uk/partnerships/working-with-patient-organisations/working-with-patients-and-patient-organisations-a-sourcebook-for-industry/payment/

iv ‌EFPIA Patient Think Tank. (2017). https://www.efpia.eu/media/288492/working-together-with-patient-groups-23102017.pdf

v EFPIA Code of Practice. (n.d.). https://www.efpia.eu/media/676434/220718-efpia-code.pdf

vi Rothenberg, S. (2010, June 28). Defending Fair Market Value (FMV) Assessments. Pharmaceutical Commerce; Pharmaceutical Commerce. https://www.pharmaceuticalcommerce.com/view/defending-fair-market-value-fmv-assessments

vii BHBIA (2017) Reversing the decline in HCP participation Initial Response Rate Task Force Report. Retrieved June 28, 2023, from https://www.bhbia.org.uk/assets/Downloads/Resources/
bhbia_response_rate_task_force-final_report_10_nov_2017_with_front_cover-(1).pdf

viii EPHMRA. (2020). Incentives Update | Ephmra.org. https://www.ephmra.org/resources-page/incentives-update