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北京市医保局、市财政局联合发布《北京市违法违规使用医疗保障基金举报奖励实施细则》，将举报最高奖励标准由10万元提高至20万元，最低奖励标准由200元提高至500元，并将针对所有违法违规使用医保基金行为的举报纳入奖励范围。对定点医疗机构、定点零售药店、医保经办机构和参保单位造成基金损失的举报，案值50万元以下，按照案值2%给予奖励；案值50万元以上的，按照案值的4%给予奖励。
The Beijing Municipal Healthcare Security Bureau and the Beijing Municipal Finance Bureau jointly issued the ‘Implementation Rules for Rewards on Reporting Illegal Use of Medical Insurance Funds in Beijing,’ raising the maximum reward for reports from 100,000 yuan to 200,000 yuan, and the minimum reward increasing from 200 yuan to 500 yuan. For reports of misuse funds caused by medical institutions, retail pharmacies, medical insurance agencies, and insured personnel, cases that have involve a value of less than 500,000 yuan, 2% of the misuse funds will be given as a reward; if the case involves more than 500,000 yuan of misused funds, 4% of the misuse funds will be given as a reward.
Medical insurance funds are currently a sensitive topic within the government, as the Administration has looked to increase the punishment of pharmaceutical enterprises that are ‘dishonest’ when it comes to handling medical insurance funds (refer to report from 27/11). Beijing’s regional Bureau has turned to the public to help them carry out more extensive supervision, as supervision over all medical institutions, pharmaceutical enterprises, and pharmacies in the region will be extremely difficult. The increased reward will obviously act as an incentive to make this happen.
国家医保局日前印发《关于加强和改进医药价格和招采信用评价工作的通知》，明确拓展价格招采信用评价的评定结果应用，在组织国家集采和省际联盟采购设置招采规则时，医保部门应充分考虑评定结果因素，对“特别严重”及“严重”失信企业实行不同程度的禁入或约束。通知明确，要强化信用评价与价格治理的协同联动，在某个省份确定失信产品价格虚高空间后，应及时通知其他省份予以关注。根据通知，要压实药品耗材生产企业公平合法诚信经营、维护正常价格秩序的第一责任。
The National Healthcare Security Administration recently issued the ‘Notice on Strengthening and Improving the Credit Evaluation of Pharmaceutical Enterprises,’ which expands the application of the evaluation results carried out by the Administration when reviewing drug prices. When organising the national medical insurance catalogue procurement process and inter-provincial procurement, the relevant government bodies should fully utilise the assessment results and implement varying degrees of bans or restrictions on companies that are ‘dishonest’ or ‘extremely dishonest.’ The Notice clarifies that it is necessary to strengthen the coordinated linkage between credit evaluation and pharmaceutical governance. After a provincial-level bureau determines that there is suspicion for higher prices or untrustworthy products, other provinces-level bureaus should also be notified in a timely manner. According to the Notice, it is necessary to consolidate the primary responsibility of pharmaceutical enterprises to operate fairly and legally to maintain normal order in the industry.
After multiple articles from state media has flagged that ‘dishonest pharmaceutical enterprises’ should be punished and banned from taking part in the government procurement process (refer to report from 24/11 and 22/11), the Administration has immediately taken action by releasing the Notice and telling regional bureaus to take reference of the credit evaluation results. The Notice has confirmed that enterprises classed as ‘dishonest’ or worse will not be given the same opportunities when taking part in the procurement process.
国家医保局公布了最新一期价格招采信用评价结果，23家失信医药企业评级为“严重”，3家为“特别严重”。所周知，失信对企业来说，是不可原谅的。药企一旦登上失信“黑名单”，轻则涉案药品或耗材的挂网、投标及配送资格被限制，重则会丧失所有药品和耗材的招采资格。从某种程度上说，这些药企可能会因为失信而被“清洗出局”。而本次曝光的26家药企中，就有3家或将面临“穷途”。为何对这些药企予以重击？原因很简单，带金销售。根据相关规定，药企可以采取终止失信行为、接受合规整改等措施主动修复信用。而随着医疗反腐持续推进，“监管之手”必然会伸向产业和市场的更细、更深处。
The National Healthcare Security Administration announced the results of the latest price and procurement credit evaluation. 23 pharmaceutical companies were rated as ‘dishonest’ and three were rated as ‘extremely dishonest.’ As we all know, the breach of trust is unforgivable. Once a pharmaceutical company is listed on the ‘dishonesty blacklist,’ its ability for selling, bidding and distributing drugs will be restricted, it could even be disqualified from all procurement processes. To some extent, these pharmaceutical companies may be ‘cleansed out’ from the industry due to the breach of trust. Among the 26 pharmaceutical companies exposed this time, three may face a ‘dead end.’ Why is there a heavy blow to these pharmaceutical companies? The reason is simple, providing kickbacks. According to relevant regulations, pharmaceutical companies can proactively repair its credit by taking measures such as accepting compliance rectification. As the anti-corruption campaign in the pharmaceutical industry continues, the ‘long arms of supervision’ will inevitably look to target the deeper parts of the industry and market.
After the Beijing Youth Post made comments on the Administration’s evaluation and said that regulators must carry out stronger supervision and punish those who try to undermine the anti-corruption campaign (refer to report from 22/11), state media continues its attack on ‘dishonest pharmaceutical enterprises.’ This article is suggesting that those who have been classed as ‘dishonest’ will basically be unable to take part in the government procurement process, greatly impacting the ability for these enterprises to sell its drugs in bulk. Another worrying sign is the article’s comments on authorities increasing its supervision efforts, which would likely confirm our previous prediction on increased supervision over the private sector.
11月21日上午，中国疾控中心病毒病所召开医药领域腐败问题集中整治工作专题会。会议传达了王贺胜局长重要讲话，并就深入落实中心党委关于集中整治工作提出的进一步深刻认识开展集中整治工作的重要性紧迫性。要不折不扣贯彻落实全面从严治党，严格执行中央八项规定及实施细则精神，扎实做好医药领域腐败问题集中整治工作。
On the morning of 21 November, the Institute of Virology of the Chinese Centre for Disease Control and Prevention held a special meeting on centralised rectification of corruption in the pharmaceutical industry. The meeting conveyed the important speech of Director Wang Hesheng and further deepened the understanding of the importance and urgency of carrying out rectification work, as well as implementing the Party Committee’s recommendations on centralised rectification work. It is necessary to implement the comprehensive and strict governance of the Party, strictly implement the eight spirits of regulation and implementation rules listed out by the Party, and carry out substantial work in the rectification of corruption in the industry.
Work meetings and conferences on the anti-corruption campaign have not been carried out by health authorities as of late. Even though the language used is highly ambiguous and does not target any specific group, the meeting would likely suggest that the government is kicking the campaign into a higher gear. Expect more news on the anti-corruption campaign to be released in the upcoming weeks.
继11月20日前董事长周军被查后，已经于去年3月退休的原副总裁顾浩亮也进入被查名单，这是半年来上海医药第六位被审查调查的管理人员。21日晚间，“廉洁上海”微信公众号发布消息称，据上海市闵行区纪委监委消息，上海医药集团股份有限公司原副总裁顾浩亮涉嫌严重违纪违法，目前正接受上海市闵行区纪委监委纪律审查和监察调查。上海医药的过往公告显示，公司原副总裁顾浩亮因退休，自2022年3月30日起不再担任公司副总裁等职务。顾浩亮自2016年8月起担任上海医药的副总裁一职直至2022年3月退休，任期超过五年。他在上海医药的另一个身份是营销中心主任。
Following the investigation of former CEO of Shanghai Pharma, Zhou Jun, on 20 November, former Vice-President of Shanghai Pharma, Gu Haoliang, has also been added to an investigation list. This is the sixth senior staff from Shanghai Pharma to be reviewed and investigated for corruption in the past six months. On the evening of 21 November, the ‘Integrity Shanghai’ WeChat public account announced that according to information from the Shanghai Minhang District Commission for Discipline Inspection and Supervision, Gu is suspected of serious violations of discipline and is currently under corruption-related investigation. Shanghai Pharma’s public announcements show that Gu has retired as the Vice-President of the company since 30 March, 2022. Gu served as the Vice-President of Shanghai Pharma from August 2016 until his retirement in March 2022. His other roles in Shanghai Pharma included being the Director of the company’s marketing centre.
The anti-corruption action against Shanghai Pharma continues. The former Vice-President of the company, who was also the Director of Marketing, is under investigation for corruption. As mentioned in yesterday’s report, Shanghai Pharma has the highest associated sales cost of any A-share pharmaceutical companies, and so it is unsurprising that the company has been targeted by anti-corruption authorities given their publicly-stated priorities.
11月20日晚间，“廉洁上海”微信公众号发布公告称，上海实业（集团）有限公司总裁周军涉嫌严重违纪违法，目前正接受上海市纪委监委纪律审查和监察调查。在今年的医药反腐风暴中，上海医药一度站上舆论的风口浪尖，这不仅与公司高额的销售费用相关，也与公司的相关人员因涉嫌严重违法违纪接受纪律审查和监察调查有关。2016年以来，上海医药的营收明显增长，从2016年的1208亿元增长到2022年的2320亿元，增幅达到92%。营收的持续增长与不断爬升的销售费用亦不无关系。上海医药的销售费用于2018年突破百亿大关，从60.67亿元攀升至142.79亿元，增幅达到135%，且2018~2022年连续五年高居A股500多家药企的榜首。
On the evening of 20 November, the ‘Integrity Shanghai’ WeChat account announced that Zhou Jun, CEO of Shanghai Pharma, is suspected of serious violations of disciplines and laws and is currently undergoing disciplinary review and investigation by the Shanghai Municipal Commission for Discipline Inspection and Supervision. During this year’s anti-corruption campaign in the pharmaceutical sector, Shanghai Pharma has once again been at the forefront of public opinion. This was not only related to the company’s high sales expenses, but also related to the fact that relevant personnel of the company have been under disciplinary review and supervisory investigation for suspected serious violations of laws and disciplines. Since 2016, Shanghai Pharma’s revenue has increased significantly, from 120.8 billion RMB in 2016 to 232 billion RMB in 2022, an increase of 92%. The continued growth in revenue is also related to the rising sales expenses. Shanghai Pharma’s sales expenses have also exceeded the 10 billion mark in 2018, climbing from 6.067 billion RMB to 14.279 billion RMB, an increase of 135%, ranking first among more than 500 A-share pharmaceutical companies from 2018 to 2022.
As expected, Zhou’s resignation is tied to corruption-related investigations. Given that Shanghai Pharma has the highest associated sales cost of any A-share pharmaceutical companies, it is unsurprising that the company has been targeted by anti-corruption authorities. With the government saying that ‘key personnel’ remain in their sights, it looks like CEOs will be the scapegoat for pharmaceutical enterprises that are in trouble. As we have consistently noted, this is not targeting foreign firms as much as local.
11月20日，国家医保局医药价格和招标采购指导中心发布了各省份评级为“特别严重”和“严重”失信的26家医药企业情况，其中23家医药企业评级为“严重”，3家医药企业评级为“特别严重”。根据信用评价目录清单，医药商业贿赂、涉税违法、实施垄断行为、不正当价格行为、扰乱集中采购秩序、恶意违反合同约定等有悖诚实信用的行为，被纳入医药价格和招采信用评价范围。对于此类失信行为，决不能姑且迁就。尤其是，当前随着相关医改的深入，也医疗反腐力度持续加强，医药商业贿赂已明显减少，现阶段出现的医药商业贿赂行为还破坏医疗反腐的大好形势，因此对于带金销售等行为，更要通过征信惩戒等方式。
On 20 November, the Drug Price Bidding and Procurement Guidance Center of the National Healthcare Security Administration released a list of 26 pharmaceutical companies that were rated as extremely dishonest’ and ‘dishonest.’ Among them, 23 pharmaceutical companies were rated as ‘dishonest’ and three were rated as ‘extremely dishonest.’ Pharmaceutical enterprises included in this list took part in commercial bribery, tax-related violations, monopoly practices, unfair pricing practices, disrupting centralised procurement processes, violated contract agreements, and other relevant behaviours that are contrary to the guidelines of pharmaceutical evaluation. Such behaviour must not be tolerated, especially due to the current medical reform and the strengthening of anti-corruption efforts in the pharmaceutical industry. The campaign has resulted in less commercial bribery happening in the sector, and such dishonest behaviour has looked to undermine the effect of the anti-corruption campaign. Therefore, it is more important to reduce dishonest behaviour in the pharmaceutical industry.
Beijing Youth Post, an important state publication that has a track record of being a leading indicator for regulatory crackdown, has stated that pharmaceutical enterprises must not commit ‘dishonest’ acts. The article has suggested that regulators must carry out stronger supervision and punish those who try to undermine the anti-corruption campaign. Even though the industry is already experiencing a crackdown on corruption, we treat this article as a likely early indicator of increased supervision on the private sector.
上海医药董事长周军因个人原因，在11月18日向董事会递交了书面辞职报告；辞任后，周军将不再担任公司及下属企业任何职务。此前，潘德青在9月1日辞职之后，即在次日因涉嫌严重违纪违法，接受纪委纪律审查和监察调查。上海医药称，周军已确认其与董事会并无意见分歧，亦不存在任何与其辞任有关的事项须提请公司股东注意；公司拥有完善的治理和管理结构，以及内部控制机制，上述事项对公司日常经营无重大影响。8月10日，针对近期持续深化的医药领域反腐，周军在2023济南生物医药与大健康产业研讨会曾表示，上海医药将全力配合，坚决落实。
Zhou Jun, Chairperson of Shanghai Pharma, submitted his resignation letter to the board of directors on 18 November 18, citing personal reasons as the reason for his resignation. After his resignation, Zhou will no longer hold any position in the company and its affiliated companies. Earlier this year, Pan Deqing, Deputy Director of Shanghai Pharma, resigned on September 1. Pan was then subjected to disciplinary review and supervisory investigation by the Central Commission for Discipline Inspection the next day on suspicion of serious corruption violations. Shanghai Pharma stated that Zhou has had no differences of opinion or arguments with the board of directors, and that the company has a complete governance and management structure, which will mean that there is no significant impact on day-to-day operations. On August 10, in response to the anti-corruption crackdown in the pharmaceutical industry, Zhou Jun stated that 2023 Shanghai Pharma will fully cooperate with relevant authorities and resolutely implement the outcomes of the crackdown at the Jinan Biomedicine and Big Health Industry Seminar.
Shanghai Pharma has already had four senior staff resign due to corruption-related investigations (refer to report from 4/9). It will be interesting to see whether Zhou’s resignation has anything to do with this. If so, it is likely that the Commission for Discipline Inspection will knock on his door very soon. As stated previously, using Party methods to combat corruption makes it more likely for domestic companies to be targeted for high-profile investigations.
据广东省纪委监委11月11日消息，广东省卫生健康委党组书记、主任朱宏涉嫌严重违纪违法，主动投案，目前正接受广东省纪委监委纪律审查和监察调查。朱宏也是近一个月内，广东医疗卫生系统落马的第二位“一把手”。今年10月19日，退休4年多的原广东省卫生和计划生育委员会主任陈元胜官宣被查。
According to the Guangdong Provincial Commission for Discipline Inspection and Supervision on 11 November, Zhu Hong, Secretary and Director of the Party Group of the Guangdong Provincial Health Commission, is suspected to have committed serious disciplinary violations. Zhu has voluntarily turned himself in and is currently undergoing disciplinary review and supervisory investigation by the Guangdong Provincial Commission for Discipline Inspection and Supervision. Zhu Hong has been the second ‘leader’ in Guangdong's healthcare system that has been investigated for corruption claims past month. On 19 October, Chen Yuansheng, former director of the Guangdong Provincial Health and Family Planning Commission, was taken in and is under investigation. Chen retired from his post back in 2019.
Zhu and Chen’s investigation suggests that the authorities are focusing its efforts on taking down leaders, which is in line with previous signals. Multiple high-profile investigations in Guangdong could suggest that corruption is particularly bad in the province. This is backed by the National Audit Office’s special audit investigation on pharmaceutical consumables in Guangdong back in May to July 2023 (refer to report from 8/8). This could be the follow up from the results obtained in the audit investigation.
医药领域反腐相关话题热度不减，备受社会各界关注。集中整治医疗领域腐败问题和不正之风，社会舆论主流声音是正面的，但其中一些杂音噪音也不容忽视，特别是一些别有用心之人趁机抨击我国医疗体制，污名化医护人员群体。整治医药领域腐败问题和不正之风，是推动健康中国战略实施、净化医药行业生态的必然要求。整治的重点要聚焦医药领域生产、供应、销售、使用、报销等重点环节和“关键少数”。
The topic of the anti-corruption campaign in the pharmaceutical industry continues to be a hot topic and has attracted attention from the public. The campaign, which focuses on addressing corruption and unhealthy practices in the industry, has an overall positive public opinion. But there are still some complaints and criticisms that cannot be ignored, especially from people with ulterior motives and have taken the opportunity to criticise China's medical system and stigmatise the medical workers. The rectification of corruption and unhealthy practices in the pharmaceutical industry is an inevitable requirement for promoting the implementation of the ‘Healthy China’ strategy and improving the entire pharmaceutical industry. The focus of the rectification process should be on key personnel such as those focusing on production, supply, sales, use, and reimbursement in the pharmaceutical industry, as well as ‘key minorities’ that have taken part in illegal activities such as ‘selling drugs by providing benefits.’
This rhetoric has been repeated many times since the start of the anti-corruption campaign, with state media stating that doctors and most people in the pharmaceutical industry should not be worried about the campaign. The message is simple: authorities will be going straight to the source. Hospital deans and executives of pharmaceutical companies who are selling into them are the main target of the anti-corruption campaign.
在医药反腐风暴席卷之下，据业内不完全统计，截至9月初，今年已有超过190位医院院长、书记和行政官员被查。10月12日，中纪委国家监委网站发布《多点发力破解一把手监督难题》一文，文章剖析了“一把手”腐败的恶劣影响和加强“一把手”监管必要性等方面的内容，将反腐矛头直接对准“一把手”和“少数关键”。资深医改专家向记者表示，这次医药反腐集中整治有三个阶段，第一个阶段自查自纠，第二个阶段深入整改，第三个阶段建章立制。现在全国各地的医药反腐可能基本处于第二个阶段，有的人觉得医药反腐好像“偃旗息鼓”了，实际上还在继续深入推进，只不过没有像第一个阶段时那样集中地曝光典型案例。
Under the anti-corruption campaign in the pharmaceutical industry, more than 190 hospital deans, secretaries, and administrative officials have been investigated as of early September. On 12 October, the Central Commission for Discipline Inspection and the National Supervision Commission released an article titled ‘Multi-Point Efforts to Solve the Difficulties in Supervising Top Leaders", which analysed the negative impact of corruption by top leaders and the necessity of strengthening supervision towards these people. The article directly targeted anti-corruption at top leaders and "a handful of key positions.’ Senior medical reform experts told reporters that the centralised rectification process for the pharmaceutical industry has three stages, starting with the self-inspection and self-correction phase, then moving to the in-depth rectification stage, and ending with the establishment of new regulations and systems. Currently, the anti-corruption campaign has reached its second stage. Some feel that the anti-corruption campaign in the pharmaceutical industry has stopped, but authorities are continuing to deepen its efforts. The difference is that authorities have not been releasing case studies as frequently as it did previously.
Even though there has not been much news on the anti-corruption campaign as of late, this is significant news. Authorities have seemingly confirmed that it will only be targeting ‘top leaders’ and those in ‘key positions,’ meaning that the heads of hospitals will be held accountable for acts that happen within their watch. The article did not mention whether the private sector will be heavily targeted or not, with the focus currently on hospital deans and secretaries — but given the number of contracts arranged with these heads of medical institutions, it is unlikely that pharmaceutical companies will be unscathed. Note also that in-depth rectification is most likely to mean stricter budget control, which may lower aggregate demand for pharmaceuticals in the short-term.
几经沉浮的医药板块近日终于回暖。细分领域中，减肥药指数表现最好，在9月6日—9月20日期间上涨7.31%，创新药指数、中药精选指数、医疗器械指数分别上涨3.95%、0.82%、0.79%。郝淼强调，在估值与情绪“戴维斯双击”作用下，带动了医药板块反弹。受此影响，医药板块下跌幅度较大。毕梦指出，今年中药板块的上涨主要集中在上半年。随着疫情的消散，需求量陆续减少，下半年中药板块持续震荡走低.
The pharmaceutical sector, which has experienced several ups and downs, has finally rebounded recently. Looking at the sub-sectors, the weight loss drug index performed the best, rising by 7.31% from September 6th to September 20th. The innovative drug index, traditional Chinese medicine selection index, and medical device indexes also rose by 3.95%, 0.82%, and 0.79%, respectively. Commentator Hao Miao emphasized that under cyclical effects of valuation and sentiment, the pharmaceutical sector rebounded and then under the usual affects, then experienced a significant decline. Another commentator Bi Meng pointed out that the rise in the traditional Chinese medicine sector this year is mainly concentrated in the first half of the year. As the epidemic dissipates, demand gradually decreases, and the traditional Chinese medicine sector continues to fluctuate and decline in the second half of the year.
While the domestic stock market is not itself a key indicator for regulation, it does influence the minds of regulators, and the reporting of this shows that despite clear signals about continuing corruption drives in the sector, the market is pricing medical devices up. This particular newspaper is signed off on by Party cadres, but is not a health newspaper. Hence this coverage shows that other parts of the system are not concerned by the crackdown as much as the health authorities.
国家卫健委领导班子调整，曾益新、雷海潮两位卫健委副主任履新卫健委党组副书记，女将河南省委常委、省纪委书记曲孝丽进京，任卫健委党组成员，卫健委纪检监察组组长。
The leadership team of the National Health Commission has been adjusted. Zeng Yixin and Lei Haichao, two deputy directors of the Health Commission, have assumed the position of Deputy Secretary of the Party Group of the Health Commission. Qu Xiaoli, a member of the Standing Committee of the Henan Provincial Committee and Secretary of the Provincial Commission for Discipline Inspection, has entered Beijing as a member of the Party Group of the Health Commission and the leader of the Discipline Inspection and Supervision Group of the Health Commission.
Qu Xiaoli is an obvious person to bring in for the ongoing crackdown. However, he is only ranked 7th in the commission itself, and is from a provincial background, and so we were expecting a more senior appointee. The two deputy directors listed above are both health care specialists.
让医生放心工作，让患者安心就医，是本轮医药反腐想要达成的目标，通过精准有效开展医药反腐，进一步推动医药卫生事业的高质量发展，营造风清气朗的执业氛围。此前召开的全国医药领域腐败问题集中整治工作视频会议也强调，针对医药领域生产、供应、销售、使用、报销等重点环节和“关键少数”。医疗领域腐败问题的存在根源是多方面的，不能简单机械地把“医药腐败”和“医生腐败”划上等号。深入有效地开展医药领域反腐，必须坚持实事求是，针对“关键少数”、关键岗位的腐败问题进行重点突破。
The goal of the anti-corruption in the pharmaceutical industry is to ensure that doctors can work with peace of mind, and patients can seek medical treatment without other worries. By accurately and effectively carrying out an anti-corruption campaign, the government can promote the high-quality development of the healthcare sector and create a clean industry. Previous instructions from the National Health Commission have mentioned that the centralised rectification program and anti-corruption campaign only focuses on key personnel and minority in the production, supply, and sales of pharmaceuticals. The root causes of corruption in the pharmaceutical industry are complicated and cannot be simplified to equate ‘medical corruption’ with ‘doctors are corrupt.’ To effectively carry out the anti-corruption campaign in the pharmaceutical industry, regulators must adhere to seeking the truth, focus on key points, and make precise efforts. We make have breakthroughs in addressing the corruption issues of key personnel and minorities.
China’s most powerful state media organ, the People’s Daily, published an article to say that the anti-corruption campaign must not look to target doctors, but instead they should go after decision makers. This was already mentioned by the National Health Commission earlier this month, however this People’s Daily shows that it has now received the official leadership imprimatur. The widespread fear sees the government telling regulators to calm down and only focus on ‘key personnel’; however, the specifics remain as per the initial National Health Commission article (see previous Daily Updates for more).
1950亿元，这是今年上半年国内药企的销售费用总和。体现在数据上，即便是海外药企巨头，销售费用往往高于研发费用。今年上半年，海外营收TOP10的药企销售管理费用率中位数为24.1%、研发费用率中位数为18.2%，国内这一中位数则分别为27.55%、7.58%。当然，透过上述数据不难看出，相比海外成熟市场，国内整体效率的提升，以及对于研发的投入与重视，依然存在很大的提升空间。理想的情况则是，销售费用日渐优化，合理的费用支出创造增长的同时，挤出更多利润投入研发，寻找更多的可能，最终药企实现销售、研发两条腿走路，而不再一高一低。目前看，不少药企正在努力优化自己的销售费用。
195 billion RMB, this is the total value of sales spending for domestic pharmaceutical enterprises in the first half of 2023. Looking at the data, sales spending is often higher than research and development expenses even for major foreign pharmaceutical enterprises. In the first half of 2023, the median sales spending and R&D spending in proportion to total spending in the top 10 foreign pharmaceutical enterprises in China stood at 24.1% and 18.2% respectively. In China, the same numbers were 27.55% and 7.58% respectively. From the data, it can be concluded that there is still great room for improvement in overall spending management for local pharmaceutical enterprises, especially in comparison to foreign pharmaceutical enterprises. The ideal scenario would see sales spending to gradually reduce, reasonable spending can create growth, and more money can be invested on R&D purposes, creating more possibilities for drug innovation. Ultimately, pharmaceutical companies will achieve a balance between sales and R&D spending, rather than having sales spending being at a much higher level. At the moment, many pharmaceutical enterprises are striving to optimise sales spending.
A useful overview of what media is allowed to report; but also should be compared to last Monday’s local government release on what the draft measures to continue the crackdown are. The measures are what matters.
在上周举办的中国医院院长论坛上，国家卫健委应急司郭燕红做了主题为“把稳政策基调，推进医药腐败集中整治”的主题报告。郭燕红提到，反腐要“集中突破，纠建并举”，要与医药界辛勤付出，不得与医务人员正收入所得相混淆，不得随意打击医务人员参加正规学术会议的积极性，不得随意夸大集中整治工作范围。报告提及“校正工作方向，对一些地方停办延办学术会议、广泛清退一线医务人员讲课费等问题及时予以纠偏”，和要“保障医院通过正常渠道进行药品、设备、耗材等采购不受影响”。
Guo Yanhong, Director of the Emergency Department of the National Health Commission, gave a keynote speech titled ‘Stabilising Policies and Promoting the Centralised Rectification of Medical Anti-Corruption’ at the China Hospital Dean Forum held last week. Guo mentioned that the anti-corruption campaign needs to be ‘focused on breakthroughs and coordinated efforts,’ which should be closely related to the work carried out in the pharmaceutical industry and should not target the justified income of those working in the industry. Guo also said that regulators and the government should attack or target medical personnel from participating in formal academic conferences, and are not allowed to arbitrarily exaggerate the scope of the anti-corruption campaign. It was mentioned during the speech that ‘the rectification work shall be corrected in a timely manner, and issues such as the suspension and postponement of academic conferences, and widespread refunds of lecture fees for frontline medical personnel should and will be addressed.’ The speech also mentioned that the campaign needs to ‘ensure that the regular process of drug, equipment, and medical consumables procurement in hospitals are not affected.’
The flipside of last Friday’s early warning signal. This is rather the signal that tells everyone what the central government does not want to see from the campaign, and what will be targeted in the next wave of the crackdown.
9月1日，陕西省西安市第一医院两名医生在医院内收受现金的视频在网络曝光. 西安市第一医院负责人表示，两名医生确为本院职工，一名为该院呼吸与危重症医学科主任，另一位为老年呼吸科原主任（退休返聘），两位当事人因违纪问题，已被停职接受调查。记者就医药代表为哪家医药公司、为何给医生送现金相关问题采访西安市第一医院负责人，该院负责人表示，网传视频中的送现金人士是医药代表，负责药品类产品，具体负责哪类药品、是哪一家公司还在落实中。调查中，记者发现，按照西安市第一医院规定，该院呼吸科病人看病过程中，药占比不得超过35%。但实际情况是，该院呼吸科患者就医过程中药占比却达到39%以上。医院负责人对此的解释是，出现这种情况和呼吸系统疾病用药相对较多有关。
西安市第一医院负责人表示，近年来，为防止发生医疗领域腐败问题，医院出台了杜绝医生收受红包和回扣的管理规定，日常管理中也有诸多切实可行的预防措施。但当记者提出查看相关材料请求后，院方表示，收集整理需要时间，未能向记者出示相关材料。
On September 1st, the video of two doctors receiving cash in the Xian no. 1 hospital was exposed on the Internet. Responsible parties said that the two doctors were indeed employees of the hospital: one was the director of the Department of Respiratory and Critical Care Medicine and the other was the former director of the Department of Geriatrics Respiratory (retired and re-employed on contract). Both have been suspended for investigation due to disciplinary problems. The reporter also interviewed the person in charge about which pharmaceutical company’s medical representatives had been selling them drugs and why they gave the cash to the doctors. According to the regulations of the First Hospital of Xi 'an, the proportion of drugs should not exceed 35% in the process of seeing a doctor. However, the actual situation is that the proportion of traditional Chinese medicine was more than 39%. The person in charge of the hospital explained that this situation is related to the relatively large use of drugs for respiratory diseases. Furthermore, they said that in recent years, in order to prevent corruption in the medical field, the hospital has issued management regulations to prevent doctors from accepting red envelopes and kickbacks, and there are also many practical preventive measures in daily management. However, when the reporter made a request to view the relevant materials, the hospital said that it took time to collect and sort out and failed to show the relevant materials to the reporter.
As we warned in our previous briefings, and indeed, this is the natural consequence of the crackdown going to the lower levels — but now the internet is being used to amplify the hunt for potential guilty parties. The usage of drugs is not apparent to be exorbitantly excessive (particularly given the case mix of the past few years), and yet this has made the national news and been heavily forwarded. It does show the importance of having records and a playbook ready should such an investigation come.
医保领域这一医疗反腐的“深水区”正在被触及。自今年8月起，有关部门将联合组织开展覆盖全国31个省和新疆生产建设兵团的医疗保障基金飞行检查。历年来的飞行检查检查出了很多问题，比如重复收费、超标准收费、分解项目收费；串换药品、医用耗材、诊疗项目和服务设施；将不属于医保基金支付范围的医药费用纳入医保基金结算；过度诊疗、过度检查、超量开药等问题。每一种乱象都影响了医保基金运转，每一个问题值得深挖根源。医疗反腐、医药反腐以及此次的医保反腐是一体的。这说明中央对这些领域的腐败零容忍，并采取有效措施清除乱象，实现源头治理。
National medical insurance funds are part of the ‘deep-end’ of the anti-corruption campaign in the health care sector, and the anti-corruption campaign for the national medical insurance funds is currently being explored. Since August, relevant government bodies have started the unannounced supervision of national medical insurance funds in 31 provinces and the Xinjiang Production and Construction corporation. Unannounced supervision of national medical insurance funds have faced many issues over the years, including repeated charges, overcharging, changing medication, covering costs for drugs that are not covered under the national medical insurance, and prescribing drugs excessively. Every single one of these problems affect the national medical insurance fund, and the root cause of it deserves to be investigated. Anti-corruption in the pharmaceutical industry, in healthcare providers, and in the national medical insurance are part of one large campaign. This shows that the central government has zero tolerance for corruption and has taken the necessary measures to eliminate all chaos at source.
As per our May 15 report on this based on the 13 May regulations release, the government has been unequivocal: the crackdown’s main target is medical insurance funds. While pharmaceutical companies have been caught up in this and investigated — plus there are listed companies, so it is easier to track the impacts of the campaign through the crash in those firms’ stock price — the government wants it to be a wholesale push to make sure that any claim on the national insurance fund will be within the parameters it wishes. The problem they face is simple; it is a system wide cost problem which doesn’t have a simple fix. So expect to see the campaign claim more scalps and be prosecuted vigorously, as everyone competes to show that they are doing something, but the target of what they do remains elusive and hard to pin down.
医药反贪风暴持续，地方政府开始把焦点放在医药企业。为规范医药领域市场秩序，近期，广州市市场监管局持续开展医药领域商业贿赂违法行为集中整治行动。如发现医药领域商业贿赂违法行为，欢迎社会各界人士向广州市市场监管局投诉举报或提供线索。线索征集时间：即日起至2023年12月31日。湖南省市场监管局也发布相似机制。
The anti-corruption campaign in the pharmaceutical industry continues, local governments are now putting the focus on pharmaceutical enterprises. In order to correct the market order of the pharmaceutical industry, the Guangdong’s Market Supervision Bureau has announced that it will continue to carry out the centralised rectification process of taking action against illegal commercial bribery in the pharmaceutical industry. The Bureau said that if anyone has leads or clues on illegal commercial bribery in the pharmaceutical industry, they are welcome to report that to the Bureau, the reporting mechanism will last to the end of 2023. Hunan’s Market Supervision Bureau has also released similar measures.
The concern of this, as we wrote last week, is that it makes targets for local governments that they then have to meet, and that raises the risks for all firms of what might happen should anyone bend the rules. This is largely a game of being seen as cleaner than anyone else, and therefore the investigators going after people other than you because they think that they are more corrupt. After this wave will nearly certainly come another group at the prefectural level who also need to institute a reporting mechanism and to send back word to Beijing that they are taking it very seriously.
辉瑞公司前全球合规分析总监Frank Han对辉瑞提起民事诉讼。在诉讼中，Han声称他因发现公司内部潜在的《反海外腐败法》(FCPA) 问题而被解雇。Han的研究发现，辉瑞在2019年第二季度至2021年第三季度期间在中国的PIGO上花费了1.68亿美元。相比之下，美国为1200万美元，加拿大为1100万美元，俄罗斯为750万美元，英国为710万美元，远超过在其他国家市场的十倍。中国作为世界上最大的药品市场之一，其市场规模庞大，并对市场准入有一定的控制。而这些控制权，掌握在某些政府官员以及相关行业里面的代表人物的手中，因此，花点钱与这些政府官员以及行业代表人物建立良好的关系无疑对辉瑞公司的市场推广和销售产生积极的影响。通过公关，辉瑞公司成功地获得了对其产品的广泛推荐和宣传，这能解释辉瑞药品价格昂贵还一药难求的原因。但我们不能忽视外国制药公司的代理人问题。他们利用资金，通过各种合法或非法手段影响决策，严重损害国家利益，甚至境外势力会利用我国法律漏洞干预政策，导致医疗领域反腐功亏一篑。
最新消息：文章自从18号发布以后，陆陆续续有更多关于辉瑞PIGO花费的文章在微信出现。但是现在还没有大型媒体发布有关文章，官方媒体还发布关于辉瑞考察团队探访无锡生产基地的正面消息。值得一提的是，现在微信搜索辉瑞后，第二个建议结果是‘辉瑞行贿1.68亿‘。
Frank Han, Pfizer’s former Director of Global Compliance Analytics, has filed a civil complaint against his previous employer in the US. Han believes that he was dismissed from his job because he found potential evidence of Foreign Corrupt Practices Act issues within the company. Han’s research found that Pfizer spent 168 million US dollars on potentially influential government officials (PIGO) in China between the second quarter of 2019 and the third quarter of 2021. During the same time period, Pfizer spent 12, 11, 7.5, and 7.1 million US dollars in the US, Canada, Russia, and the UK respectively. This shows that Pfizer’s public relations expense in China is drastically higher in China compared to other countries. As one of the countries with the largest pharmaceutical market in the world, China obviously has market entry barriers and related mechanisms put in place. Those who are in control of these entry barriers are government officials and representatives in the pharmaceutical industry. Therefore it would be helpful for Pfizer to spend some money to establish a good relationship with these government officials, which would undoubtedly have a positive impact on Pfizer’s market promotion and sales. Pfizer has successfully used its public relations expenses to gain widespread promotion of its products, which might be a possible explanation towards why its products are expensive and difficult to obtain. But the issue of foreign pharmaceutical agents using funds to influence decision makers must not be ignored, it damages national interests and can lead to foreign influences intervening with the policy making process. This can lead to the failure of the anti-corruption campaign in the pharmaceutical industry.
The social media uptake of this story concerns us. While we noted that the initial story was killed by censors, the use of social media searches, and the distinctive nature of the headline that makes it easy to find, raises the risk that Pfizer becomes something of a scapegoat in the current crackdown. The main thing is for the virality not to spread. In other words, if Pfizer responds to this in any way, then the social media searches will go, and there is a tipping point with these matters after which censors are unlikely to step in. The goal, then, is to stop the headline from circulating on WeChat social searches such that people might pick it up. One way of doing that is to engage in regular searches for other text that contains Pfizer: 辉瑞特效药 for example.
After the article was published on 18 August, there have been more and more articles covering Pfizer's PIGO expenses being published on WeChat. However, there is yet to be a major media outlet that has published an article about this yet, official media has even released welcoming news about the Pfizer delegation visiting the Wuxi production base. It is worth mentioning that after searching for Pfizer on WeChat, the second suggested result is ‘Pfizer bribery 168 million.’
中央纪律检查委员会在网站上载视频，讲解医院‘统方’行为。‘统方’是指医院人员把医生用药信息量和药单统计都发给药企，从中得到药品回扣的行为。视频说道个别党员干部利用在医院关键职务的便利，非法收集并售卖“统方”数据，收受药品销售人员送予的“统方”好处费，沦为药商的“围猎”对家，这种把“统方”数据商品化的行为终将受到严肃查处。各级纪检监察机关要加强对信息、药剂等关键岗位人员的日常监督，切实防范廉政风险，让党员干部时刻感到权力受约束，伸手必被捉。
China’s corruption combating body, the Central Commission for Discipline Inspection, posted a video on its website explaining what the ‘unified approach’ is. The ‘unified approach’ refers to hospital staff collecting doctor drug use and drug list statistics to pharmaceutical enterprises in exchange for kickbacks. The video explains that some party members and cadres are taking advantage of their position in hospitals to illegally collect and sell drug data to get benefits from pharmaceutical enterprises., making hospitals the ‘hunting ground’ for drug salespeople. The behaviour of ‘unified approach’ will be investigated and those found guilty will be severely punished. Discipline Inspection units on all levels should strengthen supervision of party members and cadres in hospitals, to effectively prevent the risk of corruption and constrain party member’s power in hospitals.
Usefully outlines what the focus of the investigators will be. Note that similar to our reporting 15 May, the focus is very clearly on party members. This puts much more pressure on domestic, onshore pharmaceutical companies.
医药企业的销售费用继续成为媒体焦点。近日，市值国内排第八的医药企业，联影医疗，发布2023年半年报。报告期内，该公司销售费用超8亿元，同比上涨55.9%。从销售费用率角度，2022年上半年，销售费用率为12.7%，而本报告期内则升至15.6%。对于销售费用的大幅增加，联影医疗表示，主要系报告期内随着业务增长销售人力成本及差旅、会务费增加。从明细来看，联影医疗的销售费用按支出比例主要包括职工薪酬费用、差旅费及交通费、保修费、会务费及业务招待费、宣传及推广费等。上半年增长幅度最为显著的是会务费及业务招待费支出金额达到0.94亿元，同比增长162.19%。伴随着销售费用提升，联影医疗上半年营业收入约为52.71亿元，同比增长26.35%；对应实现的归属净利润约为9.38亿元，同比增长21.19%。
The sales expense of pharmaceutical companies continue to be the focus of the media. Shanghai United Imaging Healthcare, which ranks eighth in market value in China’s pharmaceutical industry, released its 2023 Half-Year Report. United Imaging Healthcare reported that the sales expense during the first six months of 2023 exceeded 800 million RMB, a year-on-year increase of 55.9%. The sales-to-expense ratio for United Imaging Healthcare in 2022 stood at 12.7%, and it rose to 15.6% in the first six months in 2023. When asked about the significant increase in sales expenses, United Imaging Healthcare states that the increased wages for salespeople, and increased travel costs for conferences have contributed the most to the increased sales expense. From the sales expense breakdown, transportation costs, employee compensation, PR fees, and business entertainment expenses have also contributed to the heightened expense. The most significant increase came from business entertainment expenses, which reached 96 million yuan, a 162% increase year-on-year. With the increase in sales expense, United Imaging Healthcare’s revenue has also increased, reaching 5.27 billion yuan, a 26.4% increase year-on-year. This has translated to an increase of net profit by 21.2%, reaching 938 million yuan.
As above, it is clear that domestic firms are to be targeted for the gap between their spending on R&D and that on promotion.
随着医疗反腐逐步深入，一些模糊、错误的认识需要廓清。医疗反腐信息屡屡刷屏，有人觉得“手铐面前，医生尊严扫地，有人担心“这样下去，医生还会受人尊重吗。清除医疗领域的害群之马，营造风清气正的医疗环境，倡导健康公平的业务成长氛围，本身就是为品行高洁、业务精湛的医生创造良好的事业空间。从这个角度来说，医疗反腐是护佑医生的良知与责任，促进医疗卫生事业健康发展的必要之举。全社会都应该正确认识医疗反腐，正确看待医生这份职业。
As the anti-corruption campaign in the pharmaceutical industry continues to unravel, vague and misinterpreted information must be clarified. With people in the industry under investigation for corruption and images of hospital deans being arrested in handcuffs circulating online, the dignity of doctors has been damaged and some wonder if doctors will be disrespected by the public. Eliminating the bad apples in the industry and creating a clean environment will help promote a healthy atmosphere within the industry, which will be a good working environment for doctors who are moral. From this perspective, the campaign is a necessary step to protect the morals and responsibility of doctors, as well as promoting the healthy environment of the health care sector. The public should have a correct understanding of the campaign and respect doctors.
Doctor popularity, or lack thereof, has been an issue for much longer than the recent campaign. What is more interesting is that this campaign is being led by a different ministry (that of Labor and Human Resources) than the traditional home of doctor interest groups, the National Health and Family Planning Commission.
当前，一场力度空前的反腐风暴正在医药领域进行，公众在热议多少医院院长落马的同时，对药企合规问题也非常关注。药企合规与否、医药产品销售过程是否存在猫腻，是医药领域反腐败的重要一环。行业专家认为需要通过合规建设改变这种“带金销售”的模式。架构事前合规体系以保证销售活动合法有效，首先是药企和医院应建立公对公的销售渠道，以保证交易的透明和公正，并在此基础上，实现医药代表转型，实行医药代表单方对公（即对接医院官方而不是医生个人），或切断医药代表与某一药企的利益关系，使医药代表不再隶属于某一家药企，而是第三方机构。
An unprecedented anti-corruption campaign for the pharmaceutical industry is currently in process, the public has been active in discussing the matter and have been paying close attention to compliance issues of pharmaceutical enterprises, with the sales process of pharmaceutical enterprises playing a huge part in sparking the campaign. Experts in the industry propose that it is necessary to strengthen regulations towards pharmaceutical enterprises in order to prevent ‘bringing gold to sell.,’ by establishing a compliance system to ensure the legality and set boundaries for drug sales. This will be achieved by establishing a public sales channel for pharmaceutical enterprises and hospitals, in order to make the sales process more transparent. Pharmaceutical representatives should also sell to a board of hospital officials instead of individual doctors to eliminate hospital representatives building a relationship with certain pharmaceutical companies. In addition to that, the experts propose that pharmaceutical representatives should be provided by third party institutions to stop hospital officials from directly building relationships and contacting pharmaceutical enterprises.
We already sent this piece through on WeChat as we wanted to monitor the spread. It has already been censored and deleted online. It also appears by the number of engagements on WeChat that it was not widely spread before being censored.
8月13日，江西省医药领域腐败问题集中整治工作协作机制专班发布《江西省医药领域腐败问题集中整治工作举报方式公告》。举报对象为全省各级各类医药领域具有许可审批审核权限的行政单位，公立医疗卫生机构及社会办非营利性医疗卫生机构，接受医药领域行政部门管理指导的社会组织，医药企业以及与之相关联的经销商、医药代表等。公告发布后，已有来自龙南市第一人民医院药学部的人主动投案。线索征集时间由即日起至2024年5月底。辽宁省也设置了举报方式，列明整治时间为2023年7月至2024年6月，意味着反腐风暴应该会在明年六月结束。
On August 14, the Jiangxi Specialised Team for the Centralised Rectification Campaign of Corruption in the Pharmaceutical Industry released the ‘Notice on the Reporting Mechanism for the Centralised Rectification Campaign of Corruption in the Pharmaceutical Industry in Jiangxi.’ The targets for the reporting mechanism include administrative units with licence approval and review authority in the pharmaceutical industry, all medical and health institutions, organisations that are tied to the pharmaceutical industry, as well as representatives and sales from pharmaceutical enterprises. After the notice was released, the deputy director of the Pharmaceutical Department of Longan First People’s Hospital has turned herself in. The notice stated that the reporting mechanism will last till the end of May 2024. Liaoning Province has also set up its own reporting mechanism, specifying that the rectification period will last from July 2023 to June 2024.
Useful to have such specific dates. This would suggest that the anti-corruption campaign is very likely to end in June 2024, but given that the reporting period will still be open until then, one can expect a flood of activity near the end of the campaign in the middle of next year, as the areas that have not hit their targets ensure that they have enough cases in the system to reach their quota.
人民日报健康客户端采访了多位临床一线的普通医生，听听他们对于此次全国医药领域腐败行动的认识和感受。北京某三甲医院药剂科医生向记者透露 “这次集中整治对于我们普通医生，其实没太多影响。上述医生所在医院的取药量、就诊量并没有肉眼可见的变化，“因为该生病、该取药的患者还是需要这件事情，我们也会正常做好我们要做的事情。对我们正常的医疗工作并没有任何影响，大部分医生也秉持着治病救人的初心。”
The People’s Daily Health Blog interviewed multiple frontline doctors to listen to what they have to say about the nationwide anti-corruption campaign in the pharmaceutical industry. A doctor from a major hospital in Beijing said that ‘the anti-corruption campaign has not had much impact on regular doctors. There has been no visible change in the amount of medication taken or treated to patients in hospitals, because patients who are sick still require the same medication, and we also need to do our job properly. The campaign has no impact on our day-to-day work, and most doctors are holding the righteous mentality of treating and saving patients.’
It would be a brave doctor that said anything different; that said, physicians are not the targets of this campaign, it is rather the hospital administrators who make the purchase decisions in bulk.
市场监督管理局也进入了医药行业的反腐风暴。青海省市场监督管理局发布《关于规范医药领域经营秩序提醒告诫函》，“八禁止”提醒全省医药经营主体和广大经营者加强自律、守法经营、诚信经营，规范医药领域经营秩序。除了捆绑销售药品耗材等行为，禁止以赞助科研经费或学术会议费进行不法利益输送的行为，禁止在医药购销环节给付医院工作人员回扣和推动医药价格过快过高上涨之外，也提醒了医疗机构、广大药品经营者严格遵守《中华人民共和国反不正当竞争法》，禁止相互串通，操作市场价格。
The Administration for Market Regulation has also joined the anti-corruption campaign for the pharmaceutical industry. Qingdao’s Administration for Market Regulation issued the ‘Reminder and Warning on Standardising the Order in the Pharmaceutical Industry,’ asking that pharmaceutical enterprises in the province to strengthen self-discipline, operate according to the law, and standardise industry order. Other than telling pharmaceutical enterprises not to bundle drug selling, provide kickbacks to hospital staff by masking it as research or academic conference funds, and set excessively high prices for pharmaceuticals, the Administration also warns pharmaceutical enterprises to strictly abide by the Anti-Competition Law. The Administration warns pharmaceutical enterprises about collusion and manipulation of market price.
This is a more worrying provincial turn towards going after companies. The saving grace is that it is at the local level rather than the central signal (see our May 15 report for a far longer discussion), but still, this presages a range of investigations and possible penalties. As per yesterday’s report, given the GSK incident of 2014, ensuring adherence with general codes of conduct will be necessary in order not to provide any easy targets.
国家卫健委发布全国医药领域腐败问题集中整治工作有关问答，回答了关于反腐工作的下一步进展。卫健委表示各省份均已建立了地方医药领域腐败问题集中整治工作协作机制，制订印发地方工作方案，并召开会议进行部署安排。各地有关单位迅速开展自查自纠，处置有关问题，公布多起案例，形成严的基调和氛围，反腐已在医药行业内形成广泛共识，集中整治的各项工作正在稳步开展。下一步，集中整治工作将根据总体安排，持续推进，加大对工作的指导调度，加大对典型问题处置及通报力度，确保整治工作成效。卫健委没有进一步详细说明反腐风暴何时结束，也没有详细说明下一步的目标人群。
The National Health Commission attended a Q&A session to answer questions about the nationwide anti-corruption campaign in the pharmaceutical industry, and answered questions about the next steps of the campaign. The Commission stated that each province has already established its own mechanism for the rectification process of the pharmaceutical industry, and will carry out the tailored work plans. Relevant bodies in various regions have also started to carry out self-inspection and correction, to deal with corruption related issues. The campaign has formed a consensus within the pharmaceutical industry, and rectification work is steadily progressing. The next step is to continuously promote the campaign according to the overall work plan, increase guidance and supervision over the campaign, release typical case studies, and ensure that the campaign is effectively carried out nationwide. The Commission gave no further detail to when the campaign will end or what it will focus on next.
While there may not be a plan released, the typical case studies will give us hints as to what next. Moreover, given that they have announced it will run for a year, but are already at the provincial level, then we would expect this to reach down to the county
7月中旬以来，监管部门连续三次表达对医疗反腐的行动和决心，医药反腐风暴不断推进，不止医院书记、院长落马，在近期各地纪监部门公布的信息中，多名来自医保领域的领导干部被查。医保部门事关医保资金的监管重任，此前的医保官员腐败案就暴露出“医保领域部分干部职工利用制度漏洞监守自盗的现象依然存在”。此次多名医保局长被带走调查，就彰显为百姓看好救命钱的决心，必须从源头上揪出医保资金被套取的“医蠹”，以管住老百姓的救命钱不被滥用。政府一直在都有发表保护医疗保险基金的信息，政府这次调查多名医保部门的领导干部发出了全国性警号，要求各地领导保护医保基金，否则接受纪监部门的调查。
Since July, regulatory authorities have expressed their determination towards eliminating corruption in the pharmaceutical industry. With the anti-corruption campaign going on full strength, many hospital secretaries and deans have been under investigation. In the reports released by multiple regional Disciplinary and Inspection Commissions, regional heads of the Healthcare Security Administration are not under investigation. The Healthcare Security Administration is responsible for the supervision of medical insurance funds, but there have been many instances of staff from the Administration ‘using loopholes to steal.’ Taking regional heads of the Administration demonstrates the determination of regulatory authorities to protect valuable and life-saving funds. It is necessary to identify the cheats who have embezzled and misused medical insurance funds. The government has constantly looked to protect medical insurance funds, investigating regional heads of the Healthcare Administration sends a signal nationwide signal, safeguard the funds properly or get investigated.
This is consistent with the reporting throughout: the anti-corruption campaign is focused on the decision makers, or hospital heads, who regulators appear to view as making purchase decisions in a corrupt manner. This will of course bring much pressure on pharmaceutical companies, but as we predicted in earlier memos, the crackdown is more tightly turning the screws on hospital heads.
纪检监察机关配合开展全国医药领域腐败问题集中整治工作动员部署视频会议在京召开以来，多地纪委监委向医药腐败密集亮剑。近日，多地纪委监委就配合开展集中整治工作进行安排。
Since the Central Commission of Discipline and Inspection organised a video conference to mobilise and deploy inspections over the anti-corruption campaign for the pharmaceutical industry, many local Commissions of Discipline and Inspection have already started the process of fighting corruption. Many local Commissions have also held meetings in recent days to formalise a work plan to carry out centralised rectification of the industry.
This group will now need to report their own follow-on investigations; this is a signal that the campaign will continue for at least three months more (based on the average time for provincial-level follow up campaigns).
近期，各地医院正密集部署医药领域腐败问题专项整治工作。有医院提出整治内容主要包括四个方面：一是医药领域“红包”“回扣”问题；二是“福利式”学术培训等，以“捐赠”、学术活动、举办或参加会议、发表科研文章等名义非法输送利益，违规接受捐赠资助等问题；三是科研学术造假问题等；四是其他医药领域腐败问题。有医院鼓励和引导违规人员主动交代问题。
Hospitals across the nation are intensively deploying special rectification work plans to fight corruption in the pharmaceutical industry. Some hospitals have proposed four main points to attack: the first being the issue of accepting red envelopes, the second being the issue of using academic donations or activities to transfer benefits, the third being the issue of academic fraud in scientific research, and the fourth being corruption by other means. Hospitals are also encouraging corrupt staff to come forward and admit their mistakes proactively.
None of these actions generated by the hospitals will make much difference to the campaign: thus far, the targets have been decision makers who are choosing between different, competing tenders. Asking for pro-active admissions of guilt is a sign more of the need to hit targets and wait for the campaign to die down rather than a systematic reform.
8月8日，又有多家上市公司在沪深两市的互动平台就投资者的“反腐”提问作出回应。多家国企谈反腐, 表示反腐对合规经营企业影响有限。华润医药旗下的博雅生物回应，公司经营合法合规。国药集团旗下的国药一致表示，医药反腐利于促进医药行业健康发展，对公司业务无影响。
On 8 August, many listed pharmaceutical enterprises responded to questions regarding the anti-corruption campaign on the Shanghai and Shenzhen Stock Exchange interactive platform. State-owned pharmaceutical enterprises also chimed in, and said that the campaign has limited impact on regulation-compliant enterprises. China Resources Boya, a subsidiary under CR Pharmaceutical group, said that the company has been operating under all regulations and legal requirements. Sinopharm stated that the campaign is beneficial for promoting the healthy development of the pharmaceutical industry, and has no impact on the company’s business.
Whenever SOEs are proactively signalling that they are following an anti-corruption campaign, it’s clear that it has considerable impact. The other thing to note is that this may open SOEs up to securities disclosure problems; the SOEs are not allowed to know what the anti-corruption campaign will entail, and if they disclose information to the stock exchanges wrongly, that could possibly be taken as material.
在刚刚过去的一周，强劲的反腐风震慑整个医药行业。近年来，在医药反腐力度持续加大背景下，医院院长、书记成为被“盯紧”的对象，特别是今年开年以来，反腐风暴越刮越劲。在持续高压打击态势下，已经有一批医院“一把手”和重点岗位人员陆续落马。截至目前，全国已有150余名医院院长、书记被查。
In the past week, the anti-corruption campaign in the pharmaceutical sector has stunned the industry. Even though anti-corruption efforts have been present for several years, the past year has seen the government targeting the pharmaceutical industry in particular, with hospital deans and secretaries becoming the target of screenings. Under the high-pressure crackdown, top leaders and key members from hospitals have been found guilty of corruption and lost their jobs. As of now, more than 150 hospital deans and secretaries nationwide have been under investigation.
While this number is itself extraordinary, it also signals that the ferocity of the anti-corruption campaign is likely to ease in the next short period. One only signals the numbers of people investigated when they want to show their superiors that they have listened to the orders on what to do. Note also China’s strict liability system of corruption fighting — it holds the heads of the hospital responsible for what happens under their watch, rather than going after people doctor-by-doctor. This sends a stronger signal as to what the Party wants.
医药反腐正轰轰烈烈展开。8月7日，一张网传图片显示，近日海军军医大学第二附属医院（又名“上海长征医院”）分别向上海诺华贸易有限公司和北京诺华制药有限公司发送处理建议函，要求开除4名医药代表。
The anti-corruption campaign in the medical and pharmaceutical sector is in full swing. On 7 August, a photo from the internet shows that the Second Affiliated Hospital of Naval Medical University, otherwise known as the Shanghai Long March Hospital, has sent suggestions to Shanghai Novartis Trading and Beijing Novartis Pharmaceuticals, requesting the dismissal of four medical representatives.
A sign of the need to do something, anything, to feed the flames of showing that you are responding to the anti-corruption crackdown.
记者于近日获悉一份由国家审计署出具的广东省药品耗材专项审计调查报告显示，自2023年5月底至7月，国家审计署派出的审计组对广东省（不含深圳市）药品和高值医用耗材生产经销使用情况进行专项审计调查。发现3家药品生产企业向1936家第三方商务推广公司支付费用，假借服务费用等名义套取资金40.77亿元，增加药品综合成本，推高出厂价格。
The National Audit Office conducted a special audit investigation on drug consumables in Guangdong province from May to July 2023. The audit team dispatched by the Office specifically looked at production, product distribution, and use of high-value medical consumables in Guangdong Province. It was found that three pharmaceutical enterprises paid fees to 1936 third-party business promotion providers, and used borrowing services to extract funds worth up to 4.077 billion yuan. This has increased the cost of drug production and has increased the retail costs of drugs.
The question is not why these firms but rather why Guangdong in particular. It is not where large foreign pharmaceutical enterprises have their headquarters, and thus cannot focus on punishing the company as a whole.
近日，医药行业反腐引发市场关注，医药指数以及部分上市公司股价一度出现波动。在笔者看来，需客观看待此次反腐对医药行业的影响。与国家推行药品集中带量采购、国家医保“腾笼换鸟”一脉相承，医药行业反腐其本质是推动行业发展的公平性、合理性。
The anti-corruption campaign for the pharmaceutical industry has attracted the market’s attention as of late, which has negatively impacted the stock prices for pharmaceutical companies. In the author’s opinion, it is important to objectively see how the campaign will impact and affect the pharmaceutical industry. As China takes part in the procurement of drugs for the national medical insurance, the nature of the anti-corruption campaign is to promote fair and rational development in the pharmaceutical industry.
An official line, copying what has been passed down from above. The only benefit is that it does not seem to focus on foreigners specifically.
“今天一上午，（我所在的）一堆群都被解散了，不光是报销群，相关的项目群、会议群、沟通群等等，所有企业的相关微信群全解散了。”昨日（周五）午间，一家上市药企内部营销人员向财联社记者透露的信息，体现了近段时间“史上最强”医药反腐风暴对企业带来的冲击力。
‘This morning, all the online groups on my instant messenger apps have been deleted. Not only the sales expense group, but also groups related to the project, the conference group, and the communication group were deleted. All the records and group chats for all the pharmaceutical companies on WeChat have been deleted.’ An insider from the marketing department of a listed pharmaceutical company revealed that the industry has been facing the impacts brought from the ‘strongest anti-corruption campaign in the pharmaceutical industry to date.’
This article was redistributed and reprinted widely following publication. Later articles extended the WeChat claim to being that academic conferences have also been stalled (另据财联社7日报道，据多位业内人士表示，随着医药反腐风暴的展开，不只是医药代表群体人心惶惶，国内部分学会预定于近期召开的相关学科学术会议也集中发布通知宣告延期。据不完全统计，8月以来短短数日间，至少有10场即将举办的医药行业学术会议、论坛等宣布延期。此外，还有部分学习班、培训班也在近日宣布延期举办)。