Review Data Collection Processes for Compliant Spend Reporting

As the Life Sciences industry evolves, the significance of robust data collection processes cannot be overstated, especially when submitting open payment data to the Centers for Medicare & Medicaid Services (CMS). With regulatory scrutiny on the rise, organizations grapple with the complexities of ensuring their spend reporting practices align with the ever-evolving compliance requirements.

As we navigate the intricacies of open payments data submission to the CMS, it becomes apparent that addressing roadblocks is not merely a regulatory necessity but an obligation for life sciences companies.

Common Challenges in Spend Data Collection

1. Incomplete or Inaccurate Data

Effective spend data collection is hindered by the pervasive issue of incomplete or inaccurate information. Organizations and compliance professionals often grapple with gaps in data, whether due to inconsistent recording practices or the sheer volume of information to be managed.

This challenge not only jeopardizes the accuracy of reporting but also puts a question mark on the integrity of the entire dataset, potentially leading to compliance issues. This can be due to the organization having siloed data collection processes or because a centralized data aggregation point is missing. In any case, it is imperative to note that inaccurate data also leads to misguided decision-making and compromises your spend reports, leading to non-compliance with the CMS reporting guidelines.

2. Data Quality and Validation

The absence of standardized reporting practices poses a significant hurdle in the quest for seamless spend data collection. With diverse systems and processes in place across different departments or entities, achieving uniformity becomes a daunting task.

Organizations may face challenges in identifying and rectifying discrepancies. They require continuous quality assurance measures to maintain the reliability of collected data. The lack of standardization not only complicates data aggregation but also introduces the risk of misinterpretation and errors in the reporting process.

3. Time Sensitivity Issues with Data

Manual collection and reporting of your spend data can be quite time-consuming. Delays in collecting and validating your open payment data can impact the timeliness of reporting. Timely data is crucial for compliance, and organizations may face challenges in ensuring a swift and efficient data collection process.

Delays in data submission to regulatory bodies like the CMS can result in compliance violations and legal repercussions. CMS has already provided dates for data submission, which is before March 31 of every year, and a 45-day pre-publication review to ensure that there are no disputes in the transactions being reported to the CMS.

The challenge lies not only in the speed of data compilation but also in the coordination of various stakeholders involved in the reporting process. Overcoming this hurdle requires streamlined workflows, efficient processes, data centralization, and an aggregate spend reporting solution to identify risks associated with open payments reporting.

Why is Compliant Reporting Important?

The Physician Payments Sunshine Act, part of the Affordable Care Act, is a key regulation in the United States that emphasizes the importance of transparency and accountability in financial relationships within the healthcare sector.

Here are some reasons why compliant reporting is crucial in the U.S. life sciences industry:

• Physician Payments Sunshine Act (PPSA) Compliance: The PPSA requires applicable manufacturers of drugs, devices, biologicals, and medical supplies covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP) to report certain payments and items of value given to physicians and teaching hospitals. Compliant reporting ensures adherence to the specific requirements outlined in the PPSA.
• Avoiding Legal Consequences: Non-compliance with the reporting requirements of the PPSA can lead to legal consequences, including penalties and fines. Compliant reporting helps life sciences companies avoid legal issues and demonstrates a commitment to following the rules and regulations set forth by the government.
• Data Accuracy for Open Payments Database: The data reported under the PPSA is made publicly available on the Open Payments database. Compliant reporting ensures the accuracy and completeness of the information disclosed on this public platform, promoting transparency and allowing patients and the public to access reliable data about financial relationships in the healthcare industry.
• Industry Reputation: Adhering to compliant reporting practices contributes to a positive industry reputation. Life sciences companies that prioritize transparency and ethical conduct are likely to be viewed more favorably by healthcare professionals, patients, and the public, enhancing their overall reputation.
• Improved Stakeholder Relations: Compliant reporting helps build trust and positive relationships with healthcare professionals and organizations. When these stakeholders see that a life sciences company is transparent about its financial interactions, it fosters a sense of trust and collaboration.
• Ethical Considerations and Corporate Social Responsibility: Compliant reporting aligns with broader corporate social responsibility initiatives and ethical considerations. It demonstrates a commitment to ethical business practices and responsible engagement with healthcare stakeholders.
• Risk Management: Compliant reporting is a key component of risk management strategies. By accurately reporting financial transactions, life sciences companies can mitigate the risk of legal and regulatory issues, protecting their business interests and preserving shareholder value.

Roadblocks and Concerns in Open Payments Reporting

Compliance with Evolving Regulations

Keeping up with the changing regulatory requirements can be a significant roadblock. Navigating through complex and dynamic regulations requires constant monitoring, updates to internal processes, and ensuring that data submissions align with the latest compliance standards.

Quality and Accuracy of Data

The accuracy and quality of the submitted data are paramount. Inaccuracies, inconsistencies, or incomplete data can lead to misinformed decisions, compliance issues, and a loss of trust. Organizations must establish mechanisms to validate and ensure the integrity of the data they submit.

Diverse or Siloed Data Sources

Many organizations gather data from various sources and departments, leading to integration challenges. Ensuring seamless interoperability and data consistency across different systems is a common concern in the submission process.

Stakeholder Trust

With an effective transparency reporting process, organizations and compliance professionals can build trust among stakeholders and showcase compliant commercial activities of the business.

In the long run, this approach not only builds trust with stakeholders but also ensures a positive reputation of the company in front of the public, which contributes to building public trust.

Technological Infrastructure Limitations

Ensuring that the transparency reporting system is compatible with the format and requirements of the regulatory body can be challenging. Technical issues may arise if the system is not properly aligned with the open payment requirements.

Outdated or inadequate technological infrastructure can hinder efficient data submission, leading to delayed open payment reporting. These reports also pose the risk of being prone to errors.

Moreover, organizations may face challenges scaling their systems to handle increasing data volumes, leading to bottlenecks and inefficiencies.

Post-Submission Audits

After submission, regulatory bodies conduct audits. The CMS has its own data analytics platform to detect errors, missing entries, and other relevant aspects from the open payments data. This requires life sciences companies and compliance officers to be prepared for regulatory audits, and having systems in place to respond to inquiries is crucial.

A pro-tip here would be to have data-driven solutions in place to quickly extract and validate data reported to the CMS while showcasing adherence to rules and regulations enacted by the regulatory authorities.

How Can You Overcome These Roadblocks?

To establish robust data governance for aggregate spend reporting, organizations should create clear internal policies and procedures. These guidelines should encompass data collection, validation, storage, and reporting processes. Implementing data validation checks is crucial to guarantee the accuracy and consistency of the collected data.

Additionally, conducting regular assessments of data quality is essential, promptly addressing any issues that may arise beforehand. This approach ensures a structured and standardized framework for managing data throughout its lifecycle, contributing to reliable and compliant aggregate spend reporting.

Investing in qordata’s Aggregate Spend Reporting solution is the right way to overcome the roadblocks in CMS submission. Get complete visibility of your data to distinguish between reportable and non-reportable transactions. Be confident regarding your reports and edit multiple transactions with a few clicks.

Here’s how the solution empowers the transparency reporting process, enables life sciences companies to submit their aggregate spend data on time, and ensures no last-minute hassles in March, such as payment disputes or missing entries:

1. Upload your data in any format.
2. 400+ built-in rules to validate data.
3. CMS validation engine to detect anomalies and issues.
4. Integration with Concur, Veeva, NPPES, VPL, and NPI.
5. Enables tracking risky transactions.
6. HCPs verification for precise profiling.
7. Interactive dashboards to drive actionable insights.
8. Action center to drive issue resolution

Conclusion

In conclusion, by embracing these recommendations and adopting a proactive stance towards compliance, safeguard your organization from potential risks and solidify your reputation as a responsible and transparent entity in the marketplace. Compliant spend reporting is not just a regulatory obligation but a reflection of your commitment to integrity, accuracy, and excellence in all facets of your operations.