trends in aggregate spend and disclosure reporting and … · 2011. 3. 10. · nd . annual...

Preliminary Results 2nd Annual Industry-wide Survey

Trends in Aggregate Spend and Disclosure Reporting and Compliance – 2011 *Preliminary Results

March 2011

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Agenda

This document should not be distributed without Cegedim authorization – Copyright 2011

OverviewReporting Practices and InvestmentData Identification and HandlingPhysician Payments Sunshine ProvisionGlobal ConsiderationsConfidence in Compliance

This document should not be distributed without Cegedim authorization – Copyright 20113|

Increase in Aggregate Spend and Disclosure Laws

Transparency is becoming the ruleMany states and federal government have enacted legislation regarding disclosure of promotional spendEach law has different required information and report formatState and Federal Disclosure of Samples

New federal law adds layer of complexity

Companies will be scrutinized moreSpending information will now be available to public on the web

As a result, Life Sciences companies are required to track and report on more detailed information than ever before.


Other Considerations

Global transparency trendsPhRMA Code on Interactions with HCPsAdvaMed Code of Ethics

Anti Bribery regulations (i.e., US Foreign Corrupt Practices Act, UK Bribery Act)

OECD Convention (36 countries)

International anti-corruption instrument focused on the ‘supply side’ of the bribery transaction


Goals of the Survey

Cegedim surveyed the industry to identify current practices and expected trends around aggregate spend and disclosure reporting and compliance.Comparison to 2010 Results


OVERVIEW


Overview of Respondents

60 respondents from Pharma/Biotech/MedDevice Companies involved in ensuring their company complies with state and federal mandated aggregate spend and disclosure requirements


Departments in which respondents work

Respondents work across a number of departments with compliance making up over a third.


Company size


REPORTING PRACTICES AND INVESTMENT


How respondents currently satisfy aggregate spend and disclosure requirements

While lower than in 2010, almost a third of respondents still report using spreadsheets to comply in 2011Some respondents indicated either not satisfying requirements or avoiding promotional spend where disclosure is required


Expected plan to satisfy requirements as more laws are implemented

Most people expect to comply with either an internal or third party solution as more requirements are implementedWhile over 30% of respondents currently report manually or with spreadsheets, less than 10% say that will continue as more laws are enacted


Costs incurred from third party system implementation

Close to have half of respondents have spent between $500K and $1M on third party system implementation for aggregate spend and disclosure reporting

*New question for 2011


Employee support for aggregate spend and disclosure compliance

While the majority of respondents have 1-5 dedicated full time employees (FTEs) to support aggregate spend and disclosure compliance, there was a large increase in the number of people who reported having 6-10 FTE’s – indicating an increase in investment from 2010


Investment in aggregate spend and disclosure compliance

The majority of people expect investment in aggregate spend and disclosure compliance to increase over the next year – even more so than in 2010The most notable reason for the expected increase and investment was dealing with more requirements, including the Physician Payments Sunshine Provision


Managing resources

Based on resources, how do respondents currently manage their aggregate spend and disclosure compliance solution vs how they would prefer to?

How currently manage solution

How would prefer to manage solution



DATA IDENTIFICATION AND HANDLING


Data Identification

Compared to 2010, respondents are progressing in the process of establishing which data sources and data locations will be used in their aggregate spend and disclosure reporting


Customer master within aggregate spend solution

More companies are realizing the importance of having a customer master with only 10% reporting that they don’t have one, compared to 17% in 2010.A third of respondents have built a custom customer master solution within their aggregate spend and disclosure solution, up from 23% last year.


Associating HCPs to a state

Similar to 2010, a combination of Address and SLN is the most popular method to associate a Health Care Practitioner (HCP) to a state for reporting


Reporting of US physicians that travel abroad on your behalf

When traveling abroad on their behalf, most respondents pay physicians in the US and in US dollars



Obtaining event and spend data from vendors

About a third of respondents still obtain vendor spend data solely from spreadsheetsHowever, there is a significant increase of respondents using a combination of methods indicating that companies are becoming more flexible.


Number of HCP data sources

Overall, respondents report having more data sources related to capture HCP and Organization spend with 41% indicating having more than 10 in 2011 versus only 27% in 2010.


Challenges in consolidating spend data from multiple sources

Significant challenges remain with establishing unique Identification of an HCP and Organizations and with disparate data formats and standards


PHYSICIAN PAYMENTS SUNSHINE PROVISION


Physician Payments Sunshine Provision

More people are aware of the Physician Payments Sunshine Provision than last year

?


Level of concern with the Physician Payments Sunshine Provision

Respondents level of concern with the Physician Payments Sunshine Provision is about the same as last year


Moving from a manual solution in response to the Physician Payments Sunshine Provision

77% of respondents who currently use a manual solution to satisfy aggregate spend and disclosure requirements plan to move to an automated solution in response to the federal law (up from 64% in 2010)


GLOBAL CONSIDERATIONS


Importance of implementing a global solution

Over a third of respondents indicate that it’s a necessity to implement an aggregate spend and transparency solution that can be used in other countries across the world



Geographical priorities in a global solution

Europe and Asia Pacific are reported as priorities in respondents’ consideration of implementing a global aggregate spend and transparency solution(Please check all the apply.)



Decisions on global aggregate spend and transparency initiatives

Over half of respondents indicate that global aggregate spend and transparency initiatives originate in US offices, while 25% originate from local or regional offices



FCPA responsibilities

Only a third of respondents indicate having some responsibility for their company's compliance with FCPA (Foreign Corrupt Practices Act)



UK bribery law

About half of respondents indicate that the UK bribery law will change how they comply with current anti-bribery laws (i.e. FCPA)



Timeframe for implementing a global aggregate spend and transparency solution

The majority of respondents have not defined when they will move forward with a global solution for aggregate spend and transparency reporting



CONFIDENCE IN COMPLIANCE


Confidence in customer master to define recipient records across all data sources

Overall, respondents are only slightly more confident in the ability of their internal customer master management system to define the unique recipient records across all spend sources


Confidence in reporting process to collect all reportable recipient spend data

Respondents’ confidence in the ability of their reporting process to collect all spend data for recipients that are defined as reportable has increased over the past year

ConfidenceConfidence


Overall confidence in compliance

Respondents are slightly more confident that their company is compliant with current disclosure requirements


Causes of lack of compliance to promotional spend regulations

System/process shortcomings and poor record keeping and/or data entry continue to be the top causes of compliance issues


Email: [email protected]/compliance

Thank you…

Survey is open until March 18th.

http://surveys.cegedim.com/aggregatespend2011.aspx

trends in aggregate spend and disclosure reporting and … · 2011. 3. 10. · nd . annual...

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