Accommodation costs under the compliance lens

Support from pharmaceutical companies for medical training events promotes knowledge transfer, improves the quality of patient care and strengthens scientific exchange.
 
At the same time, such support involves legal, reputational and regulatory risks, since the pharmaceutical industry is subject to strict codes such as those of the FSA and AKG (for Germany), as well as statutory requirements and transparency obligations.
 
A common point of contention is under what circumstances accommodation costs may be covered.
 
The applicable rules on accommodation costs

  • As a rule, the scientific programme should match the participants’ professional or institutional focus and be relevant to their field.

  • Accommodation costs for one-day events may only be covered if the scientific programme lasts at least six hours. This total does not include breaks.

  • For multi-day events, the scientific programme must last at least six hours per day. The number of overnight stays covered may not exceed the number of event days.

  • For multi-day events with half-day sessions, the total scientific programme must be at least seven hours, with a minimum of two hours on the first day and four hours on the second. Accommodation costs may only be covered for the night between the two event days.

  • Different rules apply to internal training events organised by the company itself, particularly when participants play an active role through presentations or moderation. In such cases, it may be appropriate to cover overnight stays as well as travel days.

  • Transparency and documentation are essential in all cases; it must always be clear who approved the costs, which costs are covered and under what conditions.

Important considerations to ensure compliance when covering accommodation costs

  1. Assess on a case-by-case basis whether the scientific programme is relevant to each participant’s professional or institutional role.
  2. Consider the distance and return travel: is it fair and feasible for participants to return home on the same day?
  3. Assess whether an event is internal or external. Will participants be actively involved in the content, and is their attendance required across multiple sessions?
  4. Ensure accommodation is appropriate. Hotel standards, cost limits and location should be suitable for the purpose and not extravagant. Overnight stays should only be covered if they are genuinely necessary.
  5. Document and obtain approval: clearly record which costs are covered, and keep a record of both cost and event concept approvals – including any necessary disclosures to authorities – to fulfil transparency and reporting obligations.
  6. Minimise risks by avoiding any appearance of personal gain or conflict of interest. In addition, ensure that the educational event is scientifically neutral and contains no hidden promotion.

Summary: As a pharmaceutical company, you have a duty of care when covering accommodation costs. Legal requirements and industry codes allow accommodation costs to be covered only under clearly defined conditions. We’ll gladly guide you on these for each event to help you stay fully compliant.


“Good planning, clear processes and careful documentation are key to avoiding compliance risks when covering accommodation costs.”

Sarah Huch | Compliance Officer and Head of Business & Process Development

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