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

Ned Mumtaz
Written By
Ned Mumtaz
July 25, 2017

In our most recent webinar, we explored how data management processes differ in pharmaceuticals across USA. Interestingly, processes are standardized across the most compliant and transparent medical drug and device manufacturers. Based on this, we must ask: Is there one best way of going managing and leveraging spend analytics data?

Yes, accounting for differences brought in by internal policy. The processes described by our panelists, April Pierce, Chrissy Bradshaw and Elizabeth Bodine from Shire Pharmaceuticals, Porzio Bromberg, and Merz North America, respectively, had quite a few steps in common:

Information Sharing Must Be Proactive: This is important. Your audience, according to Elizabeth Bodine, need to know what they’re looking for. It could be performance figures, information related to KOL or competitive performance and so on. In Chrissy Bradshaw’s organization, this information is shared with the Executive Committee, Compliance Business Partners, Commercial and the Board of Directors. It generates interest and gives direction.

Manage The Context: A challenge that often accompanies collecting year-round datasets from disparate sources, is that the relevance of the data is often questioned, even if it should not be. Learn to manage this, with some advice here.

Reporting Is A Year Round Exercise: The Centers for Medicare & Medicaid Services (CMS) demand that pharmaceuticals should complete their reporting cycle by the 90th day of each year. I.e. 30th March. Smaller medical drug/device companies see this as leeway for leaving reporting for the last minute.


Our panelists agreed that the workload, compounded with the need to get consensus and validation is already too much on its own. “The Federal Filing (first report) by itself takes a lot of time. So you need to give yourself time before that,” said Chrissy Bradshaw. In her organization, the internal information sharing process has gone from an annual exercise to a quarterly one.

Anticipate Contingencies. Build Them Into Your Process: Sunshine Payments is still young and evolving, and this does reflect in the way pharmaceutical companies respond to its requirements. For example, the need for Sign-in Sheets for meals was a change that surfaced circa 2015, not before. It’s much more detailed now, including NPIs/license numbers and with a checkbox for opting out of meals. CIAs (Corporate Integrity Agreements) and resource (employee) shifts can also change the extent of your reporting. In many cases, people managing transparency will find it hard to trace decision documentation—to know the reporting/allocation logic behind a certain spend. Change Management principles should be an inherent part of how you approach compliance/transparency responsibilities at the group level. Documentation at every step, therefore is key. If in doubt, document it.

Third Party Vendors For Data Validation: Our panelists spoke of their reliance on third-party datasets to validate their own data. We cannot underestimate the importance of matching “what was sent” to “what we got”, but making a vendor understand its criticality isn’t always easy. It is time-consuming, and may require retraining.

More in Part II of this blog.


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.