Regulator visitors to this blog will know how important it is for qordata to get facts about pharmaceutical spend data right. We would go so far as to say that protecting the sanctity, validity, and relevance of this data has a sacred status with us.
But before data can be all this, it needs to undergo a number of internal and external processes. Unlike many of the technically sophisticated and complex processes needed for onward submission, one of the most basic and most critical requires neither.
That process is: Giving data the right context.
In a webinar-cum-discussion I hosted last month, I asked my panelists about some of the challenges they face in their organizations’ compliance programs. All three panelists, Elizabeth Bodine, Compliance Analyst, Merz – North America, Chrissy Bradshaw, Principal Porzio, Bromberg, and April Pierce, Transparency Manager, Global Reporting Shire Pharmaceuticals, had a common thread in their responses: When collecting and validating spend data, make sure you get the context right.
What does that mean, exactly?
Know Your Audience: Reports consisting of pharma spend data—do not have a single owner. They come from Corporate Finance, Business/Commercial lines, and even legal.
Some organizations (like the ones our panelists belonged to), even engage third-party vendors in an attempt to get as complete a data picture as they can. When the source and audience of a spend report are so diverse, it shouldn’t be surprising that the insights gained from the report should differ too.
Sales reps might congratulate themselves on aggressively executed campaigns—which required numerous HCP/KOL visits (and corresponding spend figures). But the same report—with the same figures—might alarm someone from legal who sees violations of internal spend limits or a precarious closeness to state level prohibitions.
For the Commercial/Planning side, the same campaign might indicate emergency adjustments to budgets or short-sightedness on the part of the sales team. Either way, each team feeds the data collection process, and to ensure that the data collected is:
- Complete
- Correct
- Accurate
It is important to give them every incentive to report figures honestly. Addressing the audiences’ individual needs and direction with empathy and a team spirit will encourage the openness needed for such data quality.
Instead of being punitive about incomplete or inaccurate data, be patient. Have individual sessions explaining the importance of data clarity and how this goes back to help and protect the business. Train your counterpart; multiple times if necessary. Understand their resource/technical shortcomings, and work around those.
Manage Expectations:
Big Pharma experience suggests that business lines tend to get defensive—even dismissive—when data presents their function in an unfavorable light. You may expect reactions like questioning the veracity of the data source, insistence on how the report is ‘incomplete’, or finding loopholes to justify the picture such data (re)presents. As a compliance/transparency professional, what are you supposed to do in such a situation?
It helps when you seek to understand before being understood. Why? Because CMS reporting is still very young and is evolving. Your business lines will not get it right the first time, and that is alright.
What this means is that you manage your own expectations from them as well as theirs of yours. As long as they know what is expected of them, as long as the direction is clear, things will work out.
For those who question data validity or find loopholes, it works if you emphasize the long term: Tell them that it is true: The data is showing an unfavorable picture of their function, but this is not destiny.
If they realistically monitor their own spend; make possible budget adjustments, or revisit the same data to identify and plug ‘problematic spend’ (i.e., questionable meal entries; poor KOL ROI, and so on), the picture CMS will receive at the end of the year may in fact reflect well on said department.
Showing them the historical patterns of the company and its competitors will also give the right context and make them less fearful.
Like our panelists, it helps to make transparency/compliance reporting a year-round responsibility. That way, you stay on top of your data, are constantly aware of activity around spend thresholds, and are in a position to forewarn business lines close to those spend thresholds.
