CMS Submissions: Inner View Vs. Outer View
“Not knowing what is in my data.”
“I don’t know how others interpret the CMS data I have submitted.”
“Have I been comprehensive enough? I can never be sure.”
These are some responses organizations specializing in pharma-compliance via data analytics receive from compliance/transparency professionals when they ask:
“What Keeps You Up At Night?”
And for pharmaceutical professionals not using a robust spend analytics platform, there’s plenty of sleep to be lost.
Fortunately, there’s an easy solution to avert the stress associated with CMS Submission. And that is: Knowing how to leverage data.
Because of the sheer volume of records entered into the CMS Database each year, (40.77 million records, on 30th June 2017), it is difficult for an organization to know everything about its own pharma spend, let alone its competitors’ or a specific specialty or category.
But knowing how to approach the data can save it from a lot of endless worry and inefficiency.
As I pointed out during qordata’s webinar on “Learning From CMS Spend Submission”, ensuring that its importance is never undermined the first step, and where managing expectations is key.
The second step is approaching the data collection/inspection process with structure. In the case of my function, I apply a ‘Divide and Conquer’ approach:
A team, or at least one dedicated resource is assigned for each spend area deemed significant based on my company’s spend interests and activities.
Data collection and cleaning is a monthly exercise, after which third-party (vendor) datasets are employed for data validation.
Continuity is a priority in this two-step process. If you collect data quarterly or annually, it becomes harder. This challenge is compounded if someone leaves.
To reduce some of this dependency, I maintain my own HCP list, and ensure that this exercise is conducted and presented each month. This gives visibility on where the HCPs are showing up.
Something I learnt when I started out in 2015 is that the evolution of the transparency/compliance role will inform the way various functions will approach data management. Without the intervention of our role, some muddling is inevitable.
To avert this, documentation, its backup, (and a backup of the backup!) is a core component of your toolkit. Don’t assume you can do without it. In my own experience, I found it difficult to find the relevant documentation straight away, but once I did, it was very helpful.
Another challenge—which later proved to be very helpful—was the development of cheat-sheets. I made these for everybody so that everyone was on the same page. Consensus on some basic things, like a standardized HCP definition can go a long way in giving clarity on what data needs to be collected and managed.