A current challenge facing bio-pharmaceutical compliance officers is to stay one step ahead of federal and state regulators' expectations for field sales practices. A proactive stance will help mitigate the severity of fines and prosecution requirements.

At a minimum, companies should comply with existing Corporate Integrity Agreement (CIAs) requirements, especially where language is repeated across several CIAs. For example, the CIAs for Novo Nordisk (2011), UCB (2011), Astra Zeneca (2010), Novartis (2010), Forest (2010), and Pfizer (2009) all contain specific requirements for field force monitoring of field sales conduct.

To meet CIA requirements for field force monitoring, companies should do the following: 

• Establish a process to monitor field sales interactions with health care providers and institutions. This should include both direct (behavior) and indirect (knowledge) observations.
• Close the loop on any potential compliance issues observed in the field by implementing effective reporting and follow-up procedures.

It is also possible to gain additional value from your field force monitoring efforts. WLH has published the following best practices on how field force monitoring can help boost
compliant sales performance: 

1. Create behavioral standards that meet both compliance and field sales performance requirements.
2. Provide behavioral-based training on these expectations that include opportunities for practice and feedback.
3. Monitor field behavior using these behavioral standards, or "inspect what you expect."
4. Link monitoring to field coaching efforts through the use of reporting and follow-up procedures. This will also reinforce the use of the behavioral standards in the field.