Like it or not, Open Payments submissions season is upon us. And that means it’s time to get serious about your company’s compliance with CMS’ rules and regulations.
With costly penalties that can go up to $1,000,000, it pays to be especially diligent. But what is the best way to check — and then double-check — that your paperwork is in order before the 31st?
Be up-front and clear about what needs to be documented.
Open Payments reporting can be a complicated process. CMS demands that certain details be documented for all transfers of value over $10. These include your company’s name, the rep’s name, and the physician’s name, just to name a few (CMS.gov, 2015). There are also 16 acceptable payment categories, and one must be chosen for each ToV. Educate (and re-educate) your reps at the beginning of each year to ensure a smoother documentation process and fewer questions down the line.
Ensure payment reports are categorized correctly.
Major hiccups can occur if a payment is recorded under the wrong category. Your sales rep may jot something down as a gift innocently enough, but if the physician on the other end of the transaction doesn’t remember things the same way, you can count on a dispute — and a raised-brow reaction from CMS. Ask your reps to verify the category of each and every transaction before you submit to minimize your risk.
Encourage honest communication between reps and physicians.
As we discussed in an earlier post about maintaining professional relationships, communication is key when it comes to avoiding Open Payments disputes. Nip potential problems in the bud by fostering an environment of open and frequent communication between your reps and the physicians and teaching hospitals they work with. This way, any issues that might arise can come to the forefront before they become compliance problems.
Make it easy to retrace your steps.
By documenting every aspect of every transaction in detail, and then compiling all of those details in one easy-to-locate place, you’ll automatically set yourself up for stress-free submissions success. If CMS comes a-knockin’ with questions about your reps’ transactions, you’ll be able to prove your company’s innocence with an accurate, time-stamped database of digital expense reporting records.
When it comes to Open Payments compliance, it’s better to be safe than $1 million in debt to CMS. Take these 4 steps to make this year’s submissions process a breeze, and be sure to check out our ebook for more tips on how you can simplify Open Payments across the board for your Life Sciences company.