Full Disclosure Ahead!

A roundtable discussion on HCP transparency


The Physician Payment Sunshine Provision of the Patient Protection and Affordable Care Act (PPACA) more commonly known as the Sunshine Act, requires manufacturers to record all transfers of value to Healthcare Professionals starting January 1, 2012 and report them to U.S. Department of Health and Human Services beginning March 31, 2013. While the preliminary requirements of the Act have been known for some time, many life sciences companies are still struggling with the operational aspects of how to achieve this new level of transparency. A growing number of state laws, some of which are more stringent than the federal requirements and the anticipation of similar regulations abroad are intensifying the challenges associated with disclosing aggregate spend even further.

Participants at a recent Deloitte roundtable discussion on Healthcare Professional (HCP) transparency outlined specific areas of concern in their journey toward full disclosure. Together, the group identified several challenges that keep them up at night when it comes to tracking and disclosing payments to covered recipients under the Act, which at present includes physicians and teaching hospitals. The discussions on how to surmount these challenges produced many insights that may be useful in helping companies not only to comply with the Sunshine Act, but also to use its penetrating rays to gain insight into opportunities to improve spend effectiveness and to gain competitive advantage.