What the Physician Payments Sunshine Act Means for Marketing Fulfillment by Jeremy Suratt

As marketers employed by pharmaceutical, biological, biomedical device and medical supply manufacturers should be aware, March 31 is the first reporting deadline for the Physician Payments Sunshine Act. Is your organization ready?

Under the Act, your company is now required to report certain payments, gifts and other transfers of value (TOVs) made to doctors and teaching hospitals ( covered recipients ). Reporting thresholds are $10 for any one payment, gift or TOV and $100 for multiple payments, gifts or TOVs in a given year.

Failure to report accurately and on time is not an option - or at least not a good option. The Act specifies penalties that can reach as high as $100,000 for each unreported payment or TOV, depending on whether your company inadvertently or knowingly failed to report it.

Sweating the Small Stuff

Tracking larger TOVs, like consulting fees, travel and so on, is tedious. But tracking promotional items and reportable marketing materials is even more laborious and time consuming. Here are three tips to help ease the tracking pains:

Tracking initial shipments: Print and promotional items are often produced in large quantities and stored by your fulfillment services partner for individual and bulk distribution to sales offices, distributors, wholesalers, marketing agents and others. Here's the good news. Your fulfillment vendor tracks and reports these orders as they're fulfilled, so you know what inventory has left the warehouse and its initial destination.

Tracking by covered recipient: Once those materials reach the party that placed the order, it's a real challenge to track dissemination to the actual end-user - which is exactly what the Sunshine Act wants to shed light on.

Did that sales rep leave just one medical journal reprint or several different promotional items at the practice she called on this morning?

Did she leave more than one copy of any item - and if so, which items specifically?

Which doctors received these materials, and how many did they receive?

Tracking distributions made by other entities: Depending on your company's relationship with third parties like distributors, wholesalers, repackagers and relabelers, you may be on the hook to report transfers of value created when they disseminate your marketing materials.

In each of these cases, it's your responsibility to gather the required names, addresses, identifying numbers and other data for each covered recipient and report it to the Centers for Medicare & Medicaid Services.

Preparing for Year Two

While you've probably developed work-a-rounds to meet this year's reporting deadline, you're undoubtedly also looking for ways to make next year's deadline less stressful - especially when it comes to tracking print materials. Here are a few ideas that will help:

Digital print: Consider using digital print to place unique tracking numbers on individual pieces shipped in bulk. Then have sales reps or others who distribute your materials record where each piece goes by item number.

Lean on your fulfillment vendor: First, ask your fulfillment services partner to configure your order system to automatically flag items used for patient education. This will make it easier for you to exclude them from reporting. Second, make sure you assign value to each piece in your inventory so that the cost of items ordered is included in your fulfillment reports.

Process: Implement a process for your reps and channel partners to provide details on the actual physicians and hospitals that received your materials. Check reports from your fulfillment vendor against distribution reports submitted by your sales reps and others, to ensure that total values tally.

The more data you can capture at the time items are ordered or distributed, the more accurate and efficient your reporting will be. So think about the information and processes that were most troubling this year and explore ways to address them with your fulfillment services company. When March 2015 rolls around, you'll be glad you did.

LINK:	http://blogs.ironmountain.com/2014/service-lines/marketing-production-...
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