What is in this article?:
Pharma companies are still struggling with how to comply with Open Payments, formerly known as the Sunshine Act section of the Patient Protection and Affordable Care Act. Here are some practical suggestions that will help.
3. Tracking Transportation
You should trace a specific transportation expense to an individual to the extent you can. For example, most limo or town-car services are assigned to a specific person. In this case, the cost should be allocated to the specific physician who took the limo or town car. If there is a shuttle, however, and there are multiple transports throughout the day, it may not be reasonably feasible to track the attendees getting off and on a bus. In this case, she said, “we take a position similar to the food and beverage guarantee scenario—the transfer of value is calculated based on guaranteed seat availability, so the eight who take the shuttle aren’t being held accountable for the 20 who didn’t.”