MSL Field Work: Proactive vs. Reactive – what is the right mix?

Over the last 10 to 20 years, the role of the Medical Science Liaison has evolved significantly. Once closely aligned with sales and marketing functions, MSL teams are now aligned with medical and clinical affairs departments and in some organizations are expressly forbidden from interacting with their commercial colleagues. This change came about as a result of increased regulatory scrutiny regarding sales and marketing activities and the need for companies to preserve their ability to educate and to provide fair balanced scientific support to healthcare providers. As corporations enter into corporate integrity agreements (CIA) with the Office of the Inspector General (OIG) many of these newer agreements expressly address the activities of medical affairs in addition to those of the commercial side of the business. The result has been increasing scrutiny regarding MSL roles and responsibilities and stricter guidances and standard operating procedures that clearly define what activities MSLs can engage in, procedures by which they are allowed to engage and how those activities should be documented.

One interesting development is that many companies now clearly delineate between which activities an MSL can engage in proactively and which activities are specifically allowed only reactively. Even more interesting is the wide variation between what is acceptable and what is not as you move from company to company. Some activities, such as responding to unsolicited requests for information, are clearly reactive only activities without exception but many other traditional MSL activities such as journal article discussions and KOL meetings are now viewed as reactive only activities or have strict rules and guidances limiting what, when and with whom these activities can take place. In the strictest of environments, all MSL engagements with healthcare providers must be reactive in nature; however, the greatest majority of companies allow MSLs some degree of proactive engagement with specific groups of healthcare providers such as identified KOL’s. To preserve the scientific integrity of the MSL organization, it is important to have a firewall between the medical and commercial teams; the question is how tall and thick should the firewall be and what type of activities constitute appropriate scientific exchange and which border on promotion disguised as education.

I am very interested to hear from MSLs and others out there:
• What activities does your organization allow proactively and which are reactive only?
• What level of documentation is required to engage in a reactive activity?
• What do you feel is the right mix between proactive and reactive activities in the daily life of the MSL?