For years, industry payments to physicians have been scrutinized by enforcement agencies, politicians and watchdog groups. In fact, the government has been playing an active role in monitoring these transfers of values for years through an increasing number of physician payment reporting laws that started with the state of Minnesota in 1993. Shortly thereafter, California, Maine, Vermont, West Virginia and the District of Columbia followed suit and by 2006, 11 additional states were proposing similar laws. This led to the passing of the U.S. Federal Sunshine Act in 2010, as well as similar laws, regulations and industry codes throughout the world.
Currently, there are physician payment “transparency” requirements in over 40 countries. This serves as continued evidence that the industry’s relationship with healthcare professionals (HCPs) make organizations vulnerable to hefty fines, reputational damage and in the worst circumstances, prosecution of individuals.
The rise in transfers of value reported through the Centers for Medicare and Medicaid Services (CMS) Open Payments portal since 2014 is a sign of the continued partnership, but also hints at the growing business complexity of managing these relationships.
Two of the top three nature-and-purpose transactions reported during 2018 are related to HCP interactions. This demonstrates the importance of applying controls throughout the engagement process to reduce the risk of improper payments.
Staying ahead of the risk curve and complying with global regulations requires appropriate controls and review processes. If you are interested in learning more, click here to download our white paper Managing the Complexities of HCP Engagements.
Diana Borges
Vice President of Compliance Solutions
March 4, 2020