Aggregate Spend Pre-Disclosure, Certification, and Disputes Management Survey Results April 3 , 2014. Introduction. Today’s Speakers. LEANNE DIDOMENICO I Philadelphia, PA Manager with 13 years of experience working with global life sciences companies
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Aggregate Spend Pre-Disclosure, Certification, and Disputes Management Survey ResultsApril 3, 2014
Today, we hope to provide insights into Huron’s 2014 Aggregate Spend Pre-Disclosure, Certification, and HCP Dispute Survey.
Specifically, the agenda is comprised of the following:
Closing remarks: Long Term Strategies To Mitigate Risk And Improve Operations
Survey OVERVIEW & METHODOLOGY
PREPARING FOR INQUIRIES & DISPUTES
#1 factor was to respond to client demand; through our own experience working with clients we were seeing common struggles and themes
Our intent was to provide real insights and data to support our clients when they make decisions across the industry as they prepare for Open Payments disclosure
Our goal is to continue to provide “quick” benchmarking as a service
Survey Overview and Methodology
Discussion of Detailed Results
The number of Covered Recipients (CRs) each company expects to report on increases dramatically with company size.
The number of employees dedicated to reporting increases with size.
There is a great deal of variation within each size group and no direct correlation with expected number of covered recipients.
Responsibility for transparency reporting continues to typically reside with Compliance:
73% of respondents indicated that business units outside of the core aggregate spend function will review data prior to reporting. Of those conducting an internal review, only 5 (out of 22) were required to do so by CIA obligations.
When setting up a program for internal certifications, companies need to consider:
Four out of five respondents rely on a manual process to complete their internal certification.
Typically, only one level of review is completed. Over 40% of respondents complete at least a second level of review beyond that.
Only 30% of respondents currently have firm plans to pre-disclose transparency data; another third have plans not to pre-disclose, and the remainder are still undecided.
For those companies undecided on their approach to pre-disclosure, consider…
The additional time now available before the line-item report is due to CMS may offer your company an opportunity to “pressure test” its dispute systems and processes prior to the formal CMS dispute window.
Only 12% of respondents have fully implemented a technological solution for managing HCP inquiries and disputes
However, around half of all respondents have a documented process in place
When preparing for inquiries & disputes, consider…
Respondents have typically allocated one or two resources to manage HCP inquiries & disputes and typically expect less than 5% of transactions to be disputed.
Most respondents have indicated they expect relatively little involvement from the sales force in resolving HCP disputes.
Long Term Strategies To Mitigate Risk & Improve Operations
Implement Monitoring Tools For Real Time Risk Tracking
HCP Not Contracted Prior to Services
Meals Above per HCP Meal Limit
Policy Limit ($)
HCP Spend ($)
“Rep A reported over HCP meal limit ($7)”
Inappropriate HCP Spend (e.g., entertainment)
Irreconcilable Sampling Inventories
Track Sampling Outliers
How can your team leverage available data to bring value to the rest of the company?
With Procurement: Identify total company-wide spend per vendor
With Sales Operations: Establish total spending on, for example, meals compared to competitor spending levels
With Clinical Ops: Compare per-subject spending with per-subject spending of peer companies (based on Aggregate Spend and ClinicalTrials.gov data)
With Sales Leadership: In conjunction with other publically available data, identify other key opinion leaders that may not have been considered by your company before
SHORT TERM HURDLES:
Setting up sustainable processes to capture external vendor’s spend data
Data Verification and Proactive Risk Mitigation
We want to hear
Submit your benchmarking ideas to firstname.lastname@example.org
by April 30 to be considered for our next benchmarking analysis.
Thank you to all the organizations who participated in Huron’s Benchmarking Survey. Your input is greatly valued, and provides critical benchmarking data for establishing best practices in an ever-changing regulatory landscape.
Please feel free to reach out to us if you have questions about the survey or if you have additional items you would like to see in 2014.
Speaker Contact Information:
Joseph Morrell, Manager
For Consultation Services Contact:
Manny Tzavlakis, Managing Director
Leanne DiDomenico, Manager