On 19 March 2020, in accordance with general social distancing precautions established by the Turkish government as a result of COVID-19, the Medicines and Medical Devices Agency prohibited product promotion representatives from making physical visits, allowing promotional activities of product promotion representatives to take place only via electronical means.
However, due to the "normalization process" in Turkey that has begun due to the decreasing number of new COVID-19 cases, the Medicines and Medical Devices Agency published an announcement on 5 June 2020 to amend the precautions for promotion representatives that had been put in place. The amendments were as follows:
From 8 June 2020, product promotion representatives have been able to engage in product promotion activities in person in primary healthcare institutions that provide diagnosis and treatment services. In terms of these activities;
- Visiting days and hours should be determined by the authorities of these centers,
- During the visits, product promotion representatives should use masks and comply with social distance and hygiene rules,
- The promotion materials and printed promotional materials should not be distributed during the visits,
- The visits should be completed as soon as possible,
- The information regarding the physician, dentist and pharmacist visited by the product promotion representative must be recorded.
From 15 June 2020, product promotion representatives have been in theory able to visit physicians, dentists and pharmacists working in other hospitals except the hospitals treating patients diagnosed with COVID-19. In addition to the listed rules above, in these visits;
- The visits shall not be made in inpatient services,
- If a decision to restrict the visit has been taken by the hospital itself, this decision should be complied.
However, all of the activities require the prerequisite of completing the trainings on infection, reduce contamination, etc. whose details are given in the notifications made to the license holders.
The promotion activities of product promotion representatives in the hospitals where COVID-19 patients are treated and for the physicians, dentists and pharmacists who do not want product promotion through the visit of product promotion representatives will be still carried out only in electronic form (e-mail, video conference) until a second announcement to be made by the Agency. In the promotion activities, the entire promotion is made only by the product promotion representative and can be done collectively for more than one physician / dentist / pharmacist provided that it is limited with the participation of physicians, dentists and pharmacists working in the same health institution.
On the other hand, there is no guidance on whether the representatives might visit the relevant authorized institutions if they did not publish any visiting hours for representatives. Accordingly, there is a need on whether such visits could be made or not in case the hospital did not publish the visiting hours.
First published by Practical Law, in 01.07.2020