Real Stories. Real World.

“I believe that everyone chooses how to approach life. If you’re proactive, you focus on preparing. If you’re reactive, you end up focusing on repairing.” – John C. Maxwell

It’s that time of year again in the aggregate spend compliance world! The time that reminds everyone involved with aggregate spend data of the importance of proactivity in ensuring data is accurate and complete. On April 1, the window opened for Open Spend Reporting disputes, and HCPs and HCOs have 45 days to review and dispute data prior to publication of data June 30. (The pharmaceutical company then has an additional 15 days to fix any disputed records.)

The goal of this review period is to provide an opportunity for pharma companies to adjust their data as necessary so that errors do not become public. Because when errors do become public, there is great risk to a pharma company from reputational damage, as well as potential fines. Equally consequential is the potential for misinforming the public about HCP/HCO relationships and where they are receiving their funding.

“Despite the many advances in aggregate spend data software – including S3 Comply’s excellent HCP HUB solution – we believe it will always take an expert, tenacious, human hand to navigate the complexities of ensuring aggregate spend data is fully analyzed, cleansed, and accurate,” said Sandy Kinsey, Chief Executive Officer.

As the Open Spend Reporting dispute resolution period winds down, this seemed like the perfect time to share insights with our existing and potential partners about what happens during this critical time – including what we do and WHY, including the proactive thinking, processes, and efforts needed to ensure pristine data.

But first…what are typical Open Spend Reporting disputes?

Since some players on the field might not be fully aware of the types of disputes that occur during this time period, here is a sampling of the data disputes from HCPs and HCOs that we see the most:

• The date on which the Transfer of Value (TOV) took place
• The HCO/HCP not recognizing the organization posting the TOV (This happens often because pharma companies often contract work to third parties, such as for clinical trials.)
• The amount of the TOV the HCO/HCP received
• Type of payment (A HCP may dispute TOV posted as “General Payment – Consulting” instead of “Research Payment” – or vice-versa. Often, this occurs because of a lack of understanding. For example, the HCP may think they are being reported, but the entry is actually research TOV reported against a HCO for which the HCP serves as a Principal Investigator.)
• Incorrect HCP/HCO reported (e.g. “John A. Smith” versus “John B. Smith”)

How are disputes typically addressed?

This one is pretty simple. Reporting representative(s) receive notification of an inquiry from Centers for Medicare and Medicaid (CMS) that a dispute has been raised and why it was raised.

But what happens from there is what separates a standard review process from a premium review process with multiple checks in place to draw the right conclusions, provide all needed documentation, and deliver peace of mind that data is fully accurate. Which leads us to…

How does S3 Comply handle Open Spend Reporting disputes?

Our favorite answer to this question is that we do everything in our power to prevent disputes in the first place!

“S3 Comply offers multiple levels of data collection and scrutiny to ensure the TOV data reported to CMS is as accurate as possible,” said Greg Warrington Senior Quality Control Data Analyst. “Our team has a series of procedures in place to discover any incorrect assessments or allocations early in the process, which greatly minimizes the potential for faulty data – thus, leading to fewer disputes.”

Again, proactivity is key. “We treat every piece of data as if it might come up in a dispute,” said Greg.

Our multiple levels of review, analysis, and cleansing include:

• An Analyst reviews all data and organizes / identifies immediate “red flags.” They ensure every line of data meets the reporting needs for our client – and in many cases, goes beyond those needs. This includes collecting all supporting documentation, including invoices, contracts, emails, etc., so the data encompasses more than just a line on a spreadsheet.
• A Quality Control Review is led by a senior level analyst with expert knowledge of CMS reporting. “Our senior analysts question anything they think could be questioned if a TOV is disputed,” said Sandy. “For example, we may have an invoice from a third-party vendor that includes payment to a particular doctor, so we work to obtain the invoice for direct payment to the doctor – which might include TOV items like meal reimbursements.”
• A Data Cleansing Process is an automated series of reports we run to identify a certain caveat of the spend (e.g. monetary vs. non-monetary TOVs). “Sometimes, it’s easier to identify errors when we’re looking at a particular cross-section of data,” said Greg. “When issues are identified at this stage, the data goes back to the Analyst and through the other processes again. Basically, we keep running the data through our cycle until we’re fully confident we have the best set of data.”

But, of course, there will always be disputes for our team to tackle for clients. Once a dispute is made, a S3 Comply senior-level manager and support team investigate the TOV and all supporting documentation.

“Our proprietary software, HCP HUB, captures all the supporting documentation and research results performed by our team,” said Sandy. “If any payment is called into question during the dispute process, we can quickly identify and extract necessary information. The workflow feature enables us to track the progression of the dispute to resolution. Built-in notification ensures that stakeholders are notified and informed throughout the process.”

If our research reveals that rectification of the allocation is indeed required, then that information is adjusted accordingly. The change is noted as “Resolved,” and our client’s attestor must validate the changed records.   

But, in many cases, our research validates the original TOV. Typically, it’s the responsibility of the Pharma company to contact the HCP/HCO and explain. The resolution will be for the party registering the dispute to either withdraw the concern (status is “Withdrawn” in CMS), or the Pharma company may acknowledge to CMS that the data should not be adjusted and is accurate (status is “Resolved No Change”).  

That said, our team often jumps in to help with communication and training as needed to address any lingering confusion with HCPs / HCOs.

“Training needs never stop, because our pharma clients are frequently changing vendors, and even with long-time vendors, new team members are joining the conversation,” said Greg. “Because of our expertise, we happy to train our clients’ partner organizations in how to provide the most accurate aggregate spend data.”

At S3 Comply, we do what we do – every step, every training, every line of data – to protect the reputations of our clients. Because back to our opening quote…it’s very difficult (if not impossible) to fully repair a damaged reputation. So, we are proud to stand as a proactive ally – before, during, and after this busy time of Open Spend Reporting disputes.

“Our clients are ultimately trusting us with their reputation in the industry and in the world – and there’s nothing more precious to us,” said Sandy. “We put our unique combination of aggregate spend expertise, our uncompromising tenacity, and unmatched processes and software solutions to work in order to support and protect our clients.”

It’s also why we love what we do – even during Open Spend Reporting dispute season!