Fair Market Value (FMV) for HCP Compensation

Published by Eunomia Pharma Services · Updated 1 October 2026

How should pharmaceutical companies determine HCP fair market value?

An HCP fair market value assessment should connect a genuine service need with the expertise, time and market context needed to deliver it. Document the benchmarking method, rate rationale, approvals and any exceptions. A rate card supports consistent decisions; it does not replace assessing whether an engagement is appropriate. Eunomia’s published case study describes one methodology across five European markets, rather than a universal HCP tariff.

What a documented FMV decision should explain

Service: the business or scientific need, expected contribution, deliverables and reasonable time commitment.
Expertise: why the selected person meets the engagement’s requirements and how any tier was assigned.
Rate: the relevant market data, calculation method, assumptions and date of the benchmark.
Governance: the approved fee, supporting contract, exception rationale where needed, and record of the work delivered.

The practical steps above are Eunomia’s operational guidance. See the source notes below for the scope of the external references.

Fair Market Value (FMV) remains one of the most scrutinised and operationally complex areas of healthcare compliance. For pharmaceutical, biotech, and medical device companies, FMV is not merely a pricing exercise, it is a core compliance control underpinning ethical engagement, anti-bribery and anti-corruption (ABAC) frameworks and transparency.

As global enforcement expectations continue to rise, regulators and self-regulatory bodies increasingly focus on how FMV is determined, documented, and applied in practice. While most large organisations have policies and structures in place, many small to medium size still struggle to translate FMV requirements into consistent, defensible, and scalable operational processes. The result is a persistent gap between written standards and day-to-day execution.

FMV in the Healthcare Context

FMV refers to the value agreed upon in an arm’s-length transaction between independent parties, where neither party can improperly influence the other. In healthcare, FMV applies when companies engage Healthcare Professionals (HCPs), Patients, Patient Representatives, members of the Public, Payers, for legitimate services such as advisory boards, speaking engagements, training, consulting, market research, scientific collaboration, etc.

The principle is clear: compensation must reflect the genuine value of services rendered and must never be linked, directly or indirectly, to inducement, prescribing, purchasing, or recommendation behaviour.

FMV therefore operates as a key safeguard within broader ABAC controls, helping mitigate risks under anti-kickback laws, bribery legislation, industry codes (EFPIA, MedTech Europe, local regulations), and global transparency and disclosure requirements.

Why FMV Is Under Heightened Scrutiny

Regulators now look well beyond the existence of an FMV policy. During audits, inspections, and investigations, organisations are expected to demonstrate:

Clearly defined and current FMV methodologies
FMV Tiering,
Consistent application across engagement types and geographies
Robust documentation, approval workflows, and audit trails
Alignment between FMV decisions and transparency disclosures

The critical question has shifted from “Do you have an FMV policy?” to “Can you clearly explain, evidence, and defend how this rate was determined?”

The Compliance and Business Impact

Poor FMV governance exposes organisations to regulatory findings, transparency discrepancies, reputational damage, and remediation costs. Equally, overly restrictive or impractical FMV approaches can hinder legitimate scientific exchange, frustrate internal stakeholders, and damage trusted relationships with HCPs.

Leading organisations are reframing FMV as an operational capability embedded within engagement, contracting, and transparency workflows. This shift requires:

Periodic review and recalibration of FMV methodologies
Clear governance aligned with ABAC and transparency frameworks
Strong documentation standards and approval controls
Integration into systems and processes used by the business

How Eunomia Supports FMV Governance and Delivery

Eunomia supports clients through clearly defined SOW-based engagements covering FMV framework design, benchmarking, governance, and operational implementation. Our services focus on building defensible FMV methodologies aligned with regulatory expectations while remaining practical for real-world use.

We assist with rate development and benchmarking, documentation standards, workflow design, exception handling, and audit readiness. Importantly, we help ensure FMV processes are aligned with transparency reporting and broader compliance programmes, including ABAC controls and third-party governance.

Conclusion

FMV is not about paying the lowest possible rate; it is about paying the right rate, for the right reason, and being able to demonstrate that decision with clarity and confidence. As expectations continue to rise, organisations must move beyond checkbox compliance and embed FMV as a transparent, well-governed, and operationally effective capability.

Eunomia partners with healthcare organisations to turn FMV from a compliance risk into a compliance strength—through structured, pragmatic, and audit-ready solutions.

How do benchmarking, rate cards and engagement assessments differ?

An FMV process needs more than a number. The tools below support different decisions and should be connected through a documented method. They do not establish a universal HCP tariff, and an amount within a benchmark range does not by itself justify an engagement.

Practical comparison: How do benchmarking, rate cards and engagement assessments differ
Tool	What it supports	What it does not establish
Benchmark dataset	Market context for comparable services.	That every observation is relevant or current.
Rate card	Consistent application of an approved method.	That a service is needed or the selected HCP is appropriate.
Engagement assessment	Application to the specific expertise, task and time.	Automatic approval of an exception.
Exception record	A reviewable explanation of a departure.	Permission to bypass required approvals.

What should a reviewer do with an unusual fee request?

Identify what is unusual before considering an exception: the expertise, geography, scope, preparation time or data coverage. Check whether the benchmark actually represents the service. Document the evidence supporting the proposed approach, the approval route and any unresolved uncertainty. Reconcile the agreed scope with the contract and the work delivered before payment. Use the worksheet as a record of the assessment, not as an automatic rate calculator. For arrangements within the ABPI Code’s scope, check the specific contracted-services requirements in Clause 24, linked below.

Use the HCP FMV assessment worksheet.

Sources and scope

PMCPA: 2024 ABPI Code, Clause 24 — Contracted Services
For arrangements within the Code’s scope, Clause 24.2 addresses legitimate need, selection, advance contracting and reasonable remuneration reflecting fair market value.

External sources accessed 28 September 2026. Check the applicable country rules and current source text for a specific engagement.

Fair Market Value (FMV) in Healthcare Compliance: Turning Regulatory Expectation into an Operational Capability