You may have noticed physician payments are in the US news yet again. Why, you may ask? More than likely this is due to the June 30, publication of the “Open Payments” data for 2015, as well as including 2013 and 2014 payment corrections. Since the beginning, medical and professional organizations including the AMA have come out in support of the transparency that publishing the data brings, however these organizations and physicians alike have also been highly critical of the accuracy of the data being published.
When you are conducting any physician-attended programs regardless if they are promotional or non-promotional in nature, it is important that you have an error-free way to capture accurate attendance information as it relates to Transfer of Value (TOV). TOV occurs for those who are paid to attend, elect to consume a meal, or are paid for their travel to/from these programs, so it is critical that this information be captured and reported correctly. Utilizing an electronic sign in process increases the success of capturing accurate information directly from the attendee, thus increasing the accuracy of your reporting. Using an electronic method that links to your reporting system eliminates the need for the company sales representative or meeting host to manually enter attendance data into your reporting system, thus minimizing errors from a manual process.
Should your current method of capturing attendance be done utilizing a paper sign-in sheet with wet signatures requiring the later manual entry of attendance and meal consumption data into an electronic system, consider the consequences. You could be putting your organization and attending HCPs at risk of having errors relating to the completeness and accuracy of reporting on both attendance and TOV.
AHM has recently conducted Attendee Data Reconciliation (ADR) audits across a few customers that currently utilize a paper sign in sheet. This is a process by which AHM compares the information populated on the paper sign-in sheet with what the sales representative entered into their system of record. The audit looked at the following data points:
- Whether there was a paper sign-in sheet available
- Compared the number of signatures obtained on the paper sign-in sheet with those marked in the system as attended
- Confirmed reportable attendee’s information on the paper sign-in sheet aligns with the correct attendees information in the system and with the appropriately aligned Customer Master ID #
- Certified that the total meal count captured in customers reporting system aligns with the number of ‘meals consumed’ denoted on the paper sign-in sheet
The results of the different audits varied, ranging from a 24% potential error rate to as high as a 95% potential error rate. The highest volume of discrepancies existed in the following areas:
- Potential mismatch in attendee name with that signed in on the paper sign-in sheet and that of selected and noted as attended within the system of record. For example:
- Christina Taylor vs. Chris Taylor
- Dr. Shaffer vs Robert Shaffer
- Misalignment of those with signatures on paper sign-in sheet and those as marked attended within the system of record. For example:
- 3 HCP signatures captured on paper sign-in sheet, however 5 HCPs captured as attended within the system of record
- Missing or inaccurate total ‘meals consumed’ count
Once the discrepancy was identified, AHM then communicated to the responsible sales representative for that program what discrepancies existed and what the appropriate actions/steps were to resolve the discrepancy. AHM then continued to follow up with the sales representative and verify the discrepancy was eventually resolved in the system of record. Unresolved discrepancies would then go to compliance for action.
Capturing attendance utilizing an electronic signature is an industry best practice, however should your organization continue to utilize paper sign-in sheets, it is vital that you implement an ADR process to minimize the risk of reporting errors. Whether you elect to audit 100% of the programs or a subset, audits are necessary to ensure the appropriate reporting for all your attendees. Sharing the audit results with your compliance team can then help drive ongoing quality assurance practices including retraining of the team managing the sign in process on-site or ongoing management of the overall percentage of paper sign-in sheets utilized that then need to be reviewed to ensure accuracy of the information captured.
Organizations can increase the accuracy of their data by transitioning to a reliable, virtually error-free electronic system of capture aligned with their data reporting system. If they are unable to transition to electronic capture, then it is critical to implement a reliable audit process to check the accuracy of both attendance and meal counts. The impacts of data errors can lead to misrepresentation of the actual spend. An error in just one to two attendees in the meal count can lead to the inaccurate reporting of TOV being reported for each attendee. Once these errors are made public it can harm a physician reputation and not only impact the professional relationship they have with their patients but also unfairly jeopardize their employment or the potential to qualify and receive research grants. All companies have an obligation to ensure the accuracy of the information provided to CMS for publication. In order to reduce the risk, organizations need to ensure accurate and timely reporting to CMS.
Debbi Koopmann, Director, Account Management, AHM
Debbi has over 17 years of experience in providing services to the Life Sciences industry working across all client functional areas including Marketing, Sales, Operations, and IT. She has a proven customer service, operations and account management background and is able to apply best practices, strategy development and proactive issue resolution in support of implementation initiatives, including the deployment of AHM’s technology solution, CentrisDirectTM.