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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.
5. Have a Dispute Resolution Plan
CMS gives physicians 45 days to dispute a transfer of value; manufacturers then have 15 days to fix it. But fixing it after the fact is not a best practice, she advised. Current thinking is to disclose the information quarterly to your HCP attendees so you have time to nip any disputes in the bud. While smaller companies likely will log disputes manually on an Excel spreadsheet, if you have the resources to do it, it’s a good idea to set up an automatic system for physicians to log into to register a dispute.
No matter how prepared you are, you likely will still have disputes once the numbers are up on the CMS Web site. It’s also a good idea to set up a customer service hotline or determine who will triage the influx of phone calls and e-mails from disgruntled physicians.
Remember that the data will be publicly available and searchable, and it will be more than just patients who will be looking at it—everyone from the Office of the Inspector General of the U.S. Department of Health and Human Services, to the IRS, to divorce attorneys will have access to the data. It’s in your and your physician attendees’ best interests to make sure the information reported is accurate.