In one of our most effective webinars this year, Wendy Derosa and Bryan Timer, both Compliance professionals at Merck USA, had useful advice for small and mid-sized pharmaceutical companies just starting out in the analytics space. Here’s what they had to say.
1. Start Small
Before the emigration to a sophisticated analytics platform, it helps to start small first. Even spreadsheet software can help you capture errors easily with filtering tools, the sorting function, and so on.
It’s a little harder to capture duplicates, given the number of transactions per month and also the fact that similar HCP names may overlap and present a confusing story to anyone doing the process manually. Nonetheless, starting small is better than not starting a compliance program at all.
2. Year-round Review
CMS Stress tends to build up in the first quarter each year. Take advantage of the rest of the year, even if the reporting cycle (for USA) is between December and March. This will give you enough legroom to explore the nature of payments, identify and remedy erroneous processes and so on.
During this review, focusing on extraordinarily high and low spend amounts, identifying missing addresses, and approaching data via ‘batches’ or ‘clusters’ are helpful directions to follow. A compliance analyst may also—resources permitting—probe via ‘people queries’ by ‘zoning in’ on specific HCPs or the following activity for a specific sales rep.
3. Document everything
Old hands in the pharma/compliance transparency space are well-acquainted with this one. Nothing, as newer compliance professionals will learn, is too small or too immaterial to ignore. Everything must be documented. It may help justify a cost or save you the reputational risk and cost involved with a CMP. In fact, if you’re following in the footsteps of Merck’s program, it would be advisable to create an ‘evidence’ folder to store such data.
4. Emphasize Process
Good analytics software makes the compliance team fairly independent. It also substantially reduces training and human error costs. For organizations who are yet to reach scale to justify their own analytics solution, emphasizing process is the way to go.
Have a visible, methodical workflow on what you’re doing month-on-month (MoM), so that in the absence of one resource, work can continue uninterrupted. This will also help you when an external stakeholder—such as an auditor—needs a walkthrough.
5. Be Sensitive To Perception
Public investigators and the media are unaware of the inner workings of your pharmaceutical company. They do not know your company’s history as well as you do. They will only learn of strategic decisions when you decide to announce them.
It is also, therefore, your responsibility to be careful about the message your data gives out. Be sensitive to the perception your data creates, and be prepared to support it with answers.
6. Business Has To Be With You On The Table
Get internal customer buy-in. The earlier, the better. They need to understand why this is important. In the pressure to meet targets, business often forgets that ethics is everyone’s responsibility. Threshold violations are everyone’s problem. Compliance isn’t a ‘necessary evil’ of pharma spend but a useful process which helps everyone do his or her job better.
7. Recruiting The Right Talent Is Key
The software will make visibility and analysis easier, but your job as a compliance professional does not end there. Hiring and then training the right talent is equally –if not more— important to keep the process on track. Quantitative and analytical skills are important, of course.
A candidate with a passion for research (qualitative data included), data engineering, and software development—will be a big plus. But the secret ingredient to building a strong compliance team is seeking people passionate about transparency. When you hire people for the right values, the right skills follow independently.
