Background:

In March 2010, Congress passed into law over 30 provisions pertaining to Healthcare Reform. Some of the laws have already gone into effect, while others will go into effect over the next 3-4 years. Many of these laws directly impact the Pharmaceutical Industry. One such legislation proposed by Congress and passed into law was The Physician Payment Sunshine Act.

This provision requires Pharmaceutical manufacturers to report all transfer of value payments exceeding $10 between manufacturers and Physicians as well as Teaching Hospitals. The purpose of this law is to provide transparency of transfer of value, or in other words, any payments to Physicians and Teaching Hospitals. These transactions must be reported by manufacturers on an annual basis beginning March 2013, and will be published to allow the public access to this information online.

Goals:

  • Ensure client is compliant with State Disclosure Laws and the Sunshine Act Federal legislation by providing robust auditing and monitoring functionality.
  • Mitigate the risk of inaccurate or incorrect HCP (Healthcare Professional) or Teaching Hospital account affiliated/group practice spend being reported.
  • Ensure all HCP PoTV transactions are captured as of January 1, 2012 to ensure client can submit data to HHS based on reporting regulations stipulated as of March, 2013.
  • Deploy an automated solution which interfaces with clients other internal solutions to effectively manage HCP and Teaching Hospital spend data collection activity.
  • Establish policies and procedures within client structure pertaining to The Sunshine Act legislation and State Disclosure laws; Implement a solution that can analyze state regulatory and Sunshine Act legislative requirements and deploy alerts and remediation workflow capabilities.

Accomplishments / Benefits:

  • Created interim solution to ensure client captures HCP Spend activity across the organization effective January 1, 2012
  • Identified potential ASC Solution to be implemented to support Sunshine Act Legislation for Aggregate Spend on a long-term basis
  • Created Aggregate Spend Solution Cross-Functional team to be the Compliance governing body for the client organization.