Concur Sheds Light on the Sunshine Act

The Physician Payment Sunshine Provision, otherwise known as the Sunshine Act, went into law in March 2010. Its aim is to monitor the influence between physicians and the manufacturers of drugs, devices or medical supplies. By requiring in-depth reporting of payments made to doctors, the expectation is to remove any hint of a conflict of interests. By shining a light on the transactions between these two groups, it attempts to limit the influence pharmaceutical companies might have on patient care and treatment.

As U.S. Senator Chuck Grassley, who sponsored the bill, said, "Transparency fosters accountability, and the public has a right to know about financial relationships." With the Sunshine Act in place, patients will have that visibility into the amounts and categories Life Sciences companies spend on health care professionals.

Reporting is key to the success of this law and the required reporting is detailed and precise. Transactions or payments that have a value greater than $10 must be reported or risk a penalty of up to $10,000 (for unknowingly reporting the transaction or payment) or $100,000 (for knowingly not reporting).

What kinds of payments or transactions need to be reported:

  • Meals
  • Gifts
  • Grants
  • In-kind contributions
  • Promotional items
  • Speaking engagement fees
  • Honorariums

What kinds of details need to be captured (at a minimum):

  • The name and address of the recipient
  • The amount and date of the payment or transfer
  • A description of the form or nature of the payment or transfer
  • Whether the payment or transfer is related to marketing, education, or research specific to a product (and the name of the product, if applicable).

The government has yet to release exactly what the full requirements will be. When they do, Concur is dedicated to insuring that those required fields are captured as well.

To help with this reporting and prevent these fines, Concur has been working closely with our pharmaceutical and medical clients to develop internal controls that support compliance as well as create accurate disclosure filings.

Attendee Tracking – uniquely identifies and tracks each attendee individually and within a given organization

Cost Limitations – allows the organization to limit the cost per attendee for a specific expense, to a set amount

Attendee Cost Associations – generates reports on specific attendee information and their associated costs to a unique expense

Cost Aggregation – tracks and aggregates the portion of expenses attributed to a given attendee as defined by a specific set of expense types for a defined period of time, typically a calendar year

Web Services – aids in the selection of the correct contacts through real-time integration with Health Care Professional databases. Avoids duplication by integrating with other systems to track interactions.

Through the month of July we’ll discuss these features and capabilities of Concur’s reporting solutions in detail to help you and your business stay compliant and penalty-free. Stay tuned.

You can find more information in our white paper, “Tracking and Reporting Health Care Professional Spend” as well as from the Pew Prescription Project.


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