“Scrutinize Your Data The Way CMS Does,” And Other Great Spend Analytics Tips-Part II

Ned Mumtaz
Written By
Ned Mumtaz
July 26, 2017

This blog follows from Part I, where we shared advice from Compliance/Transparency professionals from Shire Pharmaceuticals, Porzio Bromberg and Merz North America on how to make your datasets more robust and CMS compliant.

Treat Your Data Like Someone At The CMS Or DOJ Would: Compliance teams often focus on the supply side of spend data, i.e. presentation of their individual submissions. What recedes to the backburner in such cases is the extent of scrutiny, the search for common data culprits (e.g. missing NPIs) and the questionable records that interest authorities in CMS and the DoJ. Establish a habit of treating your data to the same scrutiny regulators would. Don’t assume that just because your numbers make sense internally, they will do so for an external viewer as well. Be relentless in questioning spend; identifying unusual patterns or deflections from the same.

Data Management Tools Help: Our panelists mentioned a number of tools that help make data compliance easier. Figuring highly in these are templates and Master Lists. The latter can be of anything—HCPs, HCOs or more sophisticated lists mapped for Sales Reps, territories or vendors for specific services. Since the Compliance/Transparency team is expected to be proactive, the onus of standardizing definitions and data journey pathways also falls on this team. In this case, it helps to develop glossaries and cheat-sheets—a one-time exercise with long-term returns.

Define Functions Clearly: What started as an audit exercise has grown into a specialized, standalone function.  Our guest blog describes how spend analytics management organized in one leading pharmaceutical. In another organization, the transparency function is part of a 12-member team placed within compliance. This team is then divided in three groups: Collection, validation and reporting. The latter is responsible for getting the data ready, and works closely with the validation group. Even external vendors have a function. From a benchmarking perspective, they fit in with compliance or corporate finance.

Data collection is considerably broader, and depends on many contributors. The degree of complexity varies too across the process—from manual, unsophisticated to automated.

Know Who Does What: Once you have defined roles, it’s time to define responsibilities. Data viewing and inspection opens your efforts to a wider audience. Reporting professionals may use analytics less than other team members, limiting them to perhaps monitoring actual spend against internal limits and State prohibitions. Analytics will also help compliance professionals in Account Management Monitoring, trend monitoring (relevant particularly for the Commercial Team in product launches), and general compliance practices.  Some organizations have dedicated CIA (Corporate Integrity Agreement) teams, and analytics go a long way in supporting them. As we mentioned earlier, data lineage goes a long way in resolving disputes when they come up.

Know What It Is Being Used For (And What It Isn’t): Some existing uses of spend analytics have been described above. What about uses that exist and remain unexplored? We could suggest some here: Early-stage Analytics: Use data on spend outliers to identify potentially problematic issues. Our panelists mentioned unusually high (or merely strange) spend figures for consulting fees and meals. Those could be a starting point for your compliance program too. Speaker/Advisory Board Monitoring: Keep visiting qordata’s Case Study section to learn how Compliance Insights helped one of our clients monitor speaker spend better—saving costs and deploying its budget far more productively.

Ned Mumtaz

About the Author

Ned Mumtaz has over 20 years of experience in the pharmaceutical industry. As the VP-Compliance, and Practice Director for Pharmaceutical Services at qordata, he is leading the transparency directive program in the US and EU.