On June 28 Glaxo SmithKline (GSK) entered into an agreement with the US Office of the Inspector General regarding various promotional activities and the cost of those activities deemed illegal.

Finally, the 3 billion dollar fine.

And I think it is unfortunate. It did not have to happen. But, during negotiation with the OIG GSK had already started to take corrective action.

By the time the agreement was made public GSK had already transformed its organization to balance the needs of the patient and the brand.

Of course, GSK is undertaking the usual compliance training and certification. Always a requirement and time consuming but the lawyers do need documentation that every employee understands the ground rules and that GSK has done its due diligence. Like many of you readers, I have been the rep or manager out in the field who has witnessed or decided against doing SOMETHING we thought was against the integrity of the US OIG Guidelines. We sometimes got pooh-poohed by our peers but we had to go with our gut and the gut was in those Guidelines and our awareness of them. I am convinced that most of us make the right decisions; that we want to do the right thing.

But, with the pressure to produce ROI, sales results AND hold on to jobs in a difficult employment environment how in the world do you stay on track. You stay on track by putting the patient into your every decision.

Ask yourself if strategy on which you are executing will really support the patient in the end. It most certainly serves your brand but does it serve your patient?

Ask yourself if you are creating value for your end-user. Hey, why not ASK your end user if what you are doing makes sense to them?

GSK continues to evolve the patient-centered approach. I hope the shareholders understand that this is a long-term strategy. It will take incredibly focused effort to change our traditional industry behavior but, I am convinced, if we know the value of this approach we can do it. We have to. We knew the future of life sciences depends on it. Now we know the OIG agrees.