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Sunshine Act Spotlights Requirement for Accurate Physician Information

The Physician Payments Sunshine Act shines a spotlight on the disorganized state of physician information, which is scattered across systems, often incomplete, inaccurate and inconsistent in most pharmaceutical and medical device manufacturing companies.

According to the recent Wall Street Journal article Doctors Face New Scrutiny over Gifts, “Drug companies collectively pay hundreds of millions of dollars in fees and gifts to doctors every year. In 2012, Pfizer Inc., the biggest drug maker by sales, paid $173.2 million to U.S. health-care professionals.”

The Risks of Creating Reports with Inaccurate Physician Information

TheSunshineAct

Failure to comply with the federal Sunshine Act opens companies up to damaging relationships with physicians they’ve spent years cultivating.

There are serious risks of filing inaccurate reports. Just imagine dealing with:

  • An angry call from a physician who received a $25 meal, which was inaccurately reported as $250 or who reportedly, received a gift that actually went to someone with a similar name.
  • Hefty fines and increased scrutiny from the Centers for Medicare and Medicaid Services (CMS). Fines range from $1,000 to $10,000 for each transaction with a maximum penalty of maximum $1.15 million.
  • Negative media attention. Reports will be available for anyone to access on a publicly accessible website.

How prepared are manufacturers to track and report physician payment information?

One of the major obstacles is getting a complete picture of the total payments made to one physician. Manufacturers need to know if Dr. Sriram Mennon and Dr. Sri Menon are one and the same.

On top of that, they need to understand the complicated connections between Dr. Sriram Menon, sales representatives’ expense report spreadsheets (T&E), marketing and R&D expenses, event data, and accounts payable data.

3 Steps to Ensure Physician Information is Accurate

In recent years, some pharmaceutical manufacturers and medical device manufacturers were required to respond to “Sunshine Act” type laws in states like California and Massachusetts. To simplify, automate and ensure physician payment reports are filed correctly and on time, they use an Aggregate Spend Repository or Physician Spend Management solution.

They also use these solutions to proactively track and review physician payments on a regular basis to ensure mandated thresholds are met before reports are due. Aggregate Spend Repository and Physician Spend Management solutions rely on a foundation of  data integration, data quality, and master data management (MDM) software to better manage physician information.

For those manufacturers who want to avoid the risk of losing valuable physician relationships, paying hefty fines, and receiving scrutiny from CMS and negative media attention, here are three steps to ensure accurate physician information:

  1. Bring all your scattered physician information, including identifiers, addresses and specialties into a central place to fix incorrect, missing or inconsistent information and uniquely identify each physician.
  2. Identify connections between physicians and the hospitals and clinics where they work to help aggregate accurate payment information for each physician.
  3. Standardize transaction information so it’s easy to identify the purpose of payments and related products and link transaction information to physician information.

Physicians Will Review Reports for Accuracy in January 2014

In January 2014, after physicians review the federally mandated financial disclosures, they may question the accuracy of reported payments. Within two months manufacturers will need to fix any discrepancies and file their Sunshine Act reports, which will become part of  a permanent archive. Time is precious for those companies who haven’t built an Aggregate Spend Repository or Physician Spend Management solution to drive their Sunshine Act compliance reports.

If you work for one of the pharmaceutical or medical device manufacturing companies already using an Aggregate Spend Repository or Physician Spend Management solution, please share your tips and tricks with others who are behind.

Tick tock, tick tock….

 

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One Response to Sunshine Act Spotlights Requirement for Accurate Physician Information

  1. Mark says:

    Thanks for the article Jakki, good overview on importance of data quality to reduce risk to pharma companies. Virtually every major pharmaceutical company has a CIA (Corporate Integrity Agreement) worked out with OIG (Office of Inspector General) regarding marketing practices, usually after multi-million dollar fine. What’s interesting is that CMS cannot even get its own house in order, but will fine any company that can’t accurately track the millions of HCPs (Health Care Providers).

    According to OIG 48 percent of records in the NPPES system (National Provider ID database) contained inaccurate data:
    http://www.oandp.com/articles/NEWS_2013-06-07_02.asp
    Keep in mind this is “official list” of providers the government maintains.

    To understand the magnitude of issue, see the link to Teaching hospital list from CMS:
    http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Teaching-Hospitals.html

    This is a spreadsheet with 1188 records. This list is also used by pharmaceutical companies to check and track any payments per Sunshine Act regulations. A quick look shows 48 records with invalid city/zip combos. Roughly 10% have serious DQ issues. See if you can find the “BATLIMORE” typo. How are companies supposed to track payments if the CMS can’t even provide correct address?

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