Who Responded to the Survey
In This Analysis
Small Teams Carry a Heavy Monitoring Load
When asked how many people handle TOV monitoring, the results reveal a significant resource gap across the industry. More than half of the organizations surveyed are relying on one or two individuals to monitor all HCP meal activity, track exceptions, and maintain audit-ready records.
At organizations with active speaker bureaus, advisory boards, and field sales teams, that workload is substantial. Manual processes under those conditions create real gaps, not because the team lacks skill, but because the volume of transactions exceeds what any small team can review thoroughly without automation.
In-Office vs. Out-of-Office Limits: Most Organizations Draw a Clear Line
That distinction reflects a practical reality: restaurant meals carry different cost structures than catered office meals, and regulators expect your limits to reflect that. The data below shows where most organizations have landed.
| Meal Type | Out-of-Office (Majority Range) | In-Office (Majority Range) |
|---|---|---|
| Dinner | $130–$15050% |
Below $7557% |
| Lunch | $45–$5056% |
$35–$4050% |
| Breakfast | $40+50% |
$25–$3044% |
How Teams Are Monitoring HCP Meal Limits
The tool mix respondents use for monitoring is worth examining carefully. The majority rely on general-purpose expense platforms rather than purpose-built compliance solutions.
Concur is a capable expense management platform, but it was not built for compliance monitoring against HCP-specific thresholds. Using it as a primary compliance tool typically requires manual configuration, custom reporting, and significant staff time to flag exceptions. Only 13% of respondents use a purpose-built tech-enabled compliance solution; that gap represents a real opportunity.
qordata's Expense Monitoring and Auditing (EMA) solution audits 100% of expense reports using AI, compared to the industry norm of reviewing only 5–10% through sampling. For teams running on Concur or Excel today, that shift in coverage is significant.
What Else Compliance Teams Are Watching
Beyond meal dollar limits, respondents identified several additional monitoring priorities. The breadth of what teams track, with small headcounts and general-purpose tools, underscores the case for automation.
Missing sign-in sheets topped the list, which aligns with what CMS expects for Open Payments reporting. Frequency monitoring, at 75%, reflects growing awareness that per-meal limits alone don't tell the full compliance story; an HCP who stays within the per-meal limit but attends 18 dinners in a year presents a different risk profile.
The fact that only 44% of respondents actively flag misclassified payments is notable. Misclassification is one of the harder issues to catch without automated review, and it sits at the intersection of Sunshine Act reporting accuracy and internal policy compliance.
What This Means for Your Compliance Program
The survey data points to a few clear patterns. Most organizations have established meal limits and are monitoring TOV in some form. The gaps tend to appear in coverage depth, not intent. Small teams using general-purpose tools like Concur or Excel are doing their best with what they have, but they cannot realistically review every transaction or catch every misclassification at volume.
If your program currently relies on sampling or manual exception review, the benchmarks above give you a useful starting point for evaluating where your limits and monitoring practices stand relative to peers. If your team is one or two people managing a high volume of HCP interactions, the case for automation is not about replacing judgment; it is about giving your team the visibility to apply that judgment where it matters most.
qordata's platform, including EMA and Compliance Central, is built for life sciences compliance teams that need to audit everything, report accurately under the Sunshine Act, EFPIA, and equivalent frameworks, and do it without adding headcount. Learn more at qordata.com.
