What is in this article?:
The Sunshine Act provisions of the Affordable Care Act are here to stay. A compliance expert opened the 2013 Pharma Forum in Orlando with a detailed look at what meeting professionals at pharmaceutical and other life sciences and medical device manufacturers need to know to keep their programs complaint.
Daniel Garen, senior vice president and chief compliance office, Wright Medical Technology, Inc.
Incorporate Sunshine Requirements Into Your Event Management Process
To meet Sunshine's requirements, meetings managers must gather data across multiple areas of spend, and often from many third-party suppliers. “Pay attention to the details,” he stressed. “What’s Dr. Smith’s NPI number, what product am I talking to him about?” Companies are counting on you to manage their events, collect and reconcile expenses, report spend into their aggregate spend system, and provide supporting documentation, he said.
For event management, you'll need to manage who is invited, both on theand attendee side, and everything to do with the venue you select, including hotel, meal, and transportation spend. You'll also have to determine how to handle invitations, and manage proof of attendance. “What if we had to have everyone in this room sign in before they came in,” he said, looking out over the crowd of some 600 people. “We would have had to start two hours early.” He added that we’ll likely see more use of badge-swiping technology to streamline the process.
And, while you don’t have to report POTOVs of less than $10 per occurrence, you still need to track even lesser amounts to be able to monitor where individual HCPs are in terms of the $100 annual cap.