Don’t let the Sunshine Act final rule catch you off guard!

The August 1st data collection deadline is just around the corner — Strategic has a simple, fast solution for QAD users and customers using Concur

On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) announced the release of the final rule implementing the physician payment sunshine provisions on Section 6002 of the Affordable Care Act (ACA), currently named The National Physician Payment Transparency Program: Open Payments. Most refer to the program as the Sunshine Act.

The intent of the Sunshine Act is to bring potential conflicts of interest to light with the goal of driving down healthcare costs. Under the new program, “applicable” manufacturers of covered drugs, devices, biological products, and medical supplies that participate in U.S. federal health care programs must annually report to the CMS information regarding payments, ownership, investment interests and other “transfers of value” to physicians and teaching hospitals. In addition, manufacturers and group purchasing organizations (GPOs) must report certain ownership interests held by physicians and their immediate family members.

Applicable manufacturers are required to begin data capture on August 1, 2013, and submit their first federal reports by March 31, 2014. Most reported information will be published by CMS on a searchable public website beginning September 30, 2014, increasing pressure to comply. CMS stated in the final rule that it will provide more information and guidance on the reporting requirements and timing of data review and correction.

These are a few of the major requirements addressed in the final rules:

  • Which payments or other transfers of value are subject to reporting, and the specific data elements that must be included for each
  • Guidelines for reporting payments that relate to research, which must be reported separately, with additional data elements including the study name and principal investigator’s name
  • Which companies must submit reports and when related entities can file joint reports or must file separately
  • Guidelines for companies that have “covered” products that are ancillary to their primary business
  • Reporting obligations for contract manufacturers, distributors and wholesalers

Since issuing the final rule in February, CMS granted six months to prepare for compliance and begin data capture. Even so, collecting the data and preparing to submit the reports is a painful process for many companies. Complying with these national disclosure requirements is a huge undertaking.

Strategic is already assisting customers to meet these new compliance requirements successfully. Planning starts with considering business processes, systems and data needs, then identifying and mapping out the program components needed to effectively source, remediate and report the required information.

Sunshine Act Compliance module key capabilities include:

  • Maintenance screens for users to create the records subject to the National Physician Payment Transparency Program.
  • Import a CSV file from Concur or other source into the maintenance screen.
  • Browse to review the payment records that have been recorded.
  • Provide integration to the Supplier Invoice Create Maintenance screen.
  • Develop the required reports for submittal (first deadline for reporting is March 31, 2014).

QAD and QAD users with the Concur add-on should take advantage of our “Sunshine Act compliance module”. The application supports the specific data collection requirements mandated in the final rule – and can be implemented very quickly to allow you to comply by the August 1 deadline. If you have any questions or doubts about how to comply with these new requirements, contact Strategic today!