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Forlì, 2 March 2018
To the 5 Star Movement
c/c FEDAIISF editorial staff
Subject: Pharmaceutical Representatives (ISF) in the M5S Health Programme
I send this note concerning the citation of the Scientific Representatives of the drug on the "Health Program" of the 5 Star Movement.
The paragraph contained in the Chapter ‘Fight against corruption and waste of the Programme, on page 9 reads: "Intervene effectively in the sector of pharmaceutical products, devices, technologies as well as research, clinical trials and training activities and related sponsorships as areas particularly exposed to the risk of corruption and conflict of interest and in this sense it appears essential to break the existing link between manufacturers of 
health products and services and the professionals who work there, forbidding any direct promotional link by companies/informants to public health operators".
I believe that the underlined part is harmful to the profession of Scientific Representatives because it generalizes and transfers a problem linked to isolated corruption phenomena, to the whole category. Furthermore, the Movement, supporting the reversal of the burden of proof, ie that the citizen is always honest until proven otherwise, with the ISF instead certifies the exact opposite: that is, all the ISF are corruptors regardless.
I propose that in the Program, the paragraph on the prevention of corruption phenomena, and conflict of interest, can be contained in the following sentence: "To intervene effectively in the sector of pharmaceutical products, devices, technologies as well as research, clinical trials and training activities and related sponsorships as areas particularly exposed to the risk of corruption and conflicts of interest".
Breaking the link between companies and professionals (ie between FSIs and Doctors), as proposed, is equivalent to suppressing the job of the informant.
The work of Pharmaceutical Representatives is governed by dozens of laws, ministerial decrees, circulars, guidelines, determinations, regulations, etc. (see Attachment). The first legal reference relating to the activity of scientific information on drugs in Italy dates back to
83 years ago, and it can be found in the Consolidated Text of the Health Laws of the Royal Decree of 27 July 1934, n.1265 (Gazz. Uff. 9 August 1934 n.186). About forty years later, the first directive of the Ministry of Health is Ministerial Circular No. 157 of 11.18.1972. After 1972, regulations multiplied. This means that over the decades, all legislators of all political alignments have constantly considered the professional figure, work and responsibility of the ISF central and fundamental.
The risk of corruption is everywhere. Specifically name the Pharmaceutical Representatives as the only spreaders of the National Health System, rather than appointing General Practitioners, Cardiology Specialists rather than Gastroenterology Specialists, Pharmacists rather than Nurses, AUSL Administrators rather than Area Managers of Pharmaceutical Companies, transmits deliberately an improper accusation because it is generalized to a single entire category, when the healthcare categories involved in corruption events are all represented. If this vision is already serious in itself, the apparent anti-constitutionality of the position of the 5 Star Movement in relation to article 4 is even more serious, and inadmissible, which reads verbatim: "The Republic recognizes all citizens The right to work and promotes the conditions that make this right effective…”.
From a statistical point of view, in the last 40 years, there have been several dozen Scientific Representatives involved in corrupt acts, i.e. they represented less than 0.2% of all the ISFs. Those found guilty, and therefore sentenced, were even fewer.
An example that arises spontaneously, on the basis of the proposal to suppress this professional figure because they are corrupt by definition, is that of suppressing, for the same reason, the figure of citizens in Parliament, because they are under investigation for corruption (and other crimes), noting the fact which in percentage terms are many more than 0.2%.
Reasoning in this way, we would find ourselves in a country without Parliament and Government and all this due to the difficulty or inability to control, prevent, isolate and seriously condemn such crimes.
The press release published on 26 February in the Parliament section of the Movimento 5 Stelle website entitled: "Health: M5S, protecting scientific whistleblowers by guaranteeing autonomy" admits the mistake by retracting the infamous sentence, and this is much appreciated, contrary to the persistent granite positions of ANAC.
The press release also changes its tone (compared to what is written in the programme) with unexpected praise for the ISF which performs a fundamental service in protecting the health of the community. The protection of the role is also positively underlined, the hope for an autonomy of the work activity, the need for transparency, the strengthening of the current legislation, the confirmation that the ISF must depend on the scientific service of the Companies holding the AIC.
Unfortunately, however, the problem remains that in the program, the paragraph in question has not yet been modified and therefore I ask myself: what is the real position of the M5S? The one proposed in the official programme, still in force a few hours after the electoral consultation which proposes the elimination of this professional figure, or that of the article "Healthcare: M5S, protecting scientific informants guaranteeing autonomy" published on the website www.movimento5stelle.it where is the ISF instead brought to the stars as a guarantor of the protection of the health of Italians?
Finally, I invite you to a meeting, organized as soon as possible in Rome, to help clarify the role of this professional figure and for a direct and transparent comparison of reciprocal positions.
Best regards.
Dr. Riccardo Bevilacqua
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