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Minimizing Risks: A Guide to Ethical HCP Engagement

Data-driven compliance solutions have proven their viability and effectiveness in the world of life science compliance over the years by enabling compliance professionals to mitigate critical risks and significantly reduce pressure.

Whether it is identifying red flags associated with engaging HCPs, pinpointing errors in an aggregate spend report prior to CMS submission, or monitoring compliance data for analysis and strengthening decision-making – it is evident that data-driven compliance is the way forward.

So, today, we’re going to shed light on one aspect of pharma compliance, that is, “HCP Engagement,” and we’re going to uncover the advantage of a data-driven HCP Engagement solution, i.e., reducing the risks of improper payments made to HCPs.

1. Efficient Annual Need Assessment (ANA)

Manual identification and documentation of commercially reasonable and legitimate purposes “need” of engaging HCPs can be challenging given that the entire process requires comprehensive data to be collected and prepared, i.e., the amount of time required, the specific date of completion, frequency of the service, budgeted expense management, progress monitoring, etc.

In addition, the process of HCP selection is yet another factor that makes HCP engagement difficult; therefore, an automated and data-driven solution that addresses all the challenges associated with need assessment would enable compliance professionals to plan present and future engagement quickly and efficiently.

With digital dashboards that allow users to review multiple HCP engagements prepared for an entire year in one place combined with controls designed to reduce third-party engagement risks, the HCP engagement process would become seamless.

2. Data-Driven HCP Screening

First and foremost comes this self-explanatory aspect. Life sciences and pharma companies use HCP Screening to identify qualified HCPs to perform specific activities.

Prior to engaging HCPs, basic due diligence is required (at minimum) to ensure that the HCPs providing services are eligible. This includes reviewing their curriculum vitae (CV), affiliation with HCOs or other organizations, specialty, medical/practitioner license validity, etc.

The reason for HCP Screening is primarily to identify the HCPs debarred by application regulatory authorities to provide services or represent an organization – such HCPs are not to be engaged.

For HCP Screening, an automated database that can be accessed to identify debarred HCPs would reduce and replace the work required to manually research, select, and include qualified HCPs per the government’s guidance.

Furthermore, with easy and quick access to a database of verified HCPs that also showcases other relevant information, i.e., the experience of the HCP, location, per hour value, expertise, domain, etc., compliance professionals would not only minimize the risk of engaging black-listed HCPs but also plan future HCP engagement activities to minimize the last-minute rush.

3. The Fair Market Value (FMV) Concern

Life sciences generally provide requirements to vendors for streamlining HCPs for activities, speaker programs, etc. HCPs are streamlined and provided to life sciences based on these requirements.

Amid the process, Fair Market Value plays an integral role. FMV is the amount paid to HCPs for consulting engagements/activities. The amount paid should never be based on the volume or value of their prescriptions according to government rules and regulations.

In addition, it is essential to ensure that an HCP is not underpaid or overpaid and that the amount paid is based on their qualification, experience, reputation in their field, and the value of their services.

A data-driven platform that would provide these essential details to compliance professionals would ensure accurate and fair payment to HCPs and eliminate the need to provide requirements to vendors for streamlining HCPs.

4. Proactive Monitoring & Auditing

With the strict rules and regulations provided by the government that are important to follow before engaging HCPs, it is imperative to continually monitor and audit an HCP engagement process.

With a data-driven digital HCP engagement solution, compliance professionals can routinely monitor and audit all their HCP engagements to identify and remediate potential issues.

Internal policies and procedures can be integrated into the platform to ensure that the process is monitored and audited according to the metrics created by the organization.

Through this efficient and data-driven monitoring and auditing of the HCP engagement process, life sciences can stay ahead of the risk curve and comply with the government’s rules and regulations.

qordata’s data-driven HCP Engage has all the features and functionalities required to ensure compliant, efficient, and effective engagement of HCPs. The solution is designed to help you manage and mitigate the complexities involved in engaging HCPs and is a one-stop data-driven compliance solution that significantly reduces pressure on internal teams while maximizing the entire HCP engagement process.

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