Ross Dworkin | Blue Grotto Technologies
To satisfy Open Payment mandates a great deal of information must be collected, verified, validated and organized. At events, meeting managers must record every transaction in a way that facilitates assignment to multiple participants. Attendance details must be thoroughly recorded for the main event as well as any sub-event. Attendee identities should be validated and include NPI numbers (and, depending on other technology, state license information).
Ultimately, attendance and spending information must be properly stored and organized to satisfy various (and frequently changing) compliance regulations while making it available for an audit at any time.
This task isn’t simple. Events may be comprised of multiple activities such as a reception, meal, focus group or instruction, and not every attendee participates in each activity. These activities have costs associated with them. Hence, proper spend assignment requires you to know the exact subset of attendees that participated in each sub-event, as well as how to assign portions of specific expenditures to a specific activity. Unfortunately, many of the invoices you receive will be complex: sent by a vendor for a service that spans several activities or participants (“value recipients”).
This article summarizes technologies helpful for the Sunshine Act reporting process, which include:
Data Capture Technology: Technologies that capture information, often on site and in real-time. These technologies, such as Concur® and Sign4Compliance,® often manage work flow and operate on mobile devices. They offer expense reporting, attendance, registration and additional, similar functions.
Master Data Management (MDM): These systems are used to maintain records of health care professionals (HCP). Specifically, MDM systems update HCP records using data streams from multiple sources including state and federal agencies and commercial services. The “Master List” maintained by a MDM will often be used as the base for a Client Relationship Management system and/or used to remediate names captured by other means (i.e., event registration systems or sign-in sheets).
Client Relationship Management (CRM): Used to manage and record HCP/client interactions. This includes scheduling calls, selecting clients for events, and recording interactions. The difference between a CRM and a MDM is that CRMs operate on a subset of HCPs and usually store, track and operate on data created by internal interactions and events. Whereas MDMs operate on a broader list of HCPs and collect data generated by other systems and outside services.
Commercial Databases: Maintain lists of HCPs used for lookup when ascertaining a provider’s identity, or reconciling existing information for a specific HCP. Often, companies providing commercial databases will sell a data remediating service to validate reported information. Although the government is offering its “Validated Physician Lists,” most of the commercial lists, such as Medpro, also include mid-level professionals (NPs, PAs) and state specific identifiers.
Aggregate Spend Systems: Used to process spend data and manage the submission process to CMS and various state organizations. These systems will often apply rules to your data, flag any problems, then submit spend data to federal and appropriate state governments.
Spend Analytic Tools: Used to proactively and retrospectively view spend data. These tools can alert you to outlier situations such as meetings with too high a spend per participant or when cumulative spending for a specific HCP exceeds a set amount. These tools can also leverage your spend data to compare vendors and relationships with HCPs. When linked to the general CMS data (everyone’s reported spend data), analytic tools can be used to compare your HCP spend with competitor spend and help you identify HCPs receiving high spend from both you and your competitor.
These technologies work best when they are integrated into your IT environment and used to facilitate the process of collecting, verifying, organizing, submitting and analyzing your spend data. However, effectively implementing these technologies is no easy task. It requires consultative input from technically skilled experts that understand technology, your relevant internal processes, and how your compliance department designates transactions be handled and assigned.