As the clock ticks down to the 2012 deadline to begin tracking everything they spend on healthcare providers to comply with the provisions of the Sunshine Act, are pharmaceutical, medical device, or other life sciences companies ready to adopt transparency in their financial relationships with HCPs? According to the results of a pre-con survey of participants who are gathered this week at the Hilton San Diego Bayfront Hotel for the Fourth Annual Life Sciences Meeting Management Forum, the answer would appear to be "yes."

Eighty-eight percent said they had a system already to track their spend on physicians and other healthcare professionals, and 76 percent were either already testing their system or were confident that their system was ready to roll with the new year. However, it quickly became apparent that the same can't be said for physicians, contract research organizations, and others involved in pharmaceutical and other life sciences meetings. As one attendee said, "Are physicians ready for this? I'd say hands-down no." This is despite the fact that it will be physicians, along with other healthcare providers, whose earnings from pharma meetings will be posted publicly on Web sites once the act becomes fully implemented in 2013. As for those firms that life sciences companies contract to help with their clinical trials? As one participant said, "CROs don't have a clue this applies to them."

Hoteliers and other suppliers, who could and, said many meeting management professionals at the conference, should be vital compliance assistants, all too often don't understand the rigors of pharma and other life sciences meetings these days. As one participant noted, "Whether you just support us, or whether you change the way to do your billing to itemize everything, or provide a special pharma F&B menu that takes our limitations into account, suppliers can play a key role."

Other findings of interest from the survey:
- 65 percent of respondents reported an annual meeting spend of more than $1 million; 26 percent said it was more than $10 million.
- 36 percent had no plans to implement a strategic meetings management process; 14 percent were in the SMM planning phase, while 23 percent were implementing their SMM, and 27 percent had fully launched SMMPs.
- Compliance remains the top challenge. Other challenges they noted included cost management, short lead times, knowing what to report, and dealing with multiple stakeholders.

CMS Proposes Rule
Conference-goers also got some big news yesterday as the Centers for Medicare and Medicaid Services released its long-awaited proposed rule for the Physician Payment Sunshine Act. Under the rule, drug and device manufacturers must disclose any single payments to physicians of $10 or more, or aggregate payments of more than $100 per physician, to CMS.

Those who fail to report will be subject to penalties up to $150,000 annually; those who knowingly fail to report could face civil monetary penalties of up to $1,000,000.

The newly released rule also pushes the deadline for data collection from January 1, 2012, until after the final regulations are issued. CMS is accepting comments on the proposed rule until February 17, 2012.