How to prepare for the global healthcare transparency phenomenon

With the March 31st Open Payments deadline behind us, Concur customers in the medical device and pharmaceutical industries can breathe a big sigh of relief. But it’s important not to get too comfortable. The “phenomenon” of global transparency regulations in healthcare is gaining momentum, and life sciences companies doing business abroad need to be ready for regulations governing transfers of payment to healthcare providers and healthcare organizations in countries outside the U.S. In fact, a Deloitte study reported that 70 percent of pharmaceutical sales will occur in countries with healthcare provider transparency regulations already in effect in 2015.


Here’s a look at how global transparency regulations are unfolding:

The U.S. Sunshine Act, which was adopted in 2011, was followed by the adoption of French Law No. 2011-2012, the Strengthening of Health Protection for Medicinal and Health Products decree, also referred to as Loi Bertrand or the French Sunshine Act.



Other transparency regulations governing transfers of value and payments are also in effect in Portugal, Denmark, Slovakia and the Netherlands. Japan has a voluntary disclosure code for both pharmaceutical and medical device manufacturer association members. And Australia and Columbia have pending regulations similar to the U.S. Open Payments law.



By June 2016, the European Federation of Pharmaceutical Industries and Associations’ (EFPIA) Disclosure Code will require transparency disclosures for the 2015 calendar year by all members, who span 33 European countries, including the U.K., Sweden, Norway, Switzerland, Germany and Spain.



As global transparency laws continue to evolve, it has become clear that life sciences companies need access to global healthcare provider data — stat!



Where to get global healthcare data is the big question, though. Most data providers don’t have it. Another important question is, “Can the global data provider meet the nuances of global transparency regulations?” Some countries not only require tracking payments to Physicians, Dentists and Pharmacists, but also Nurses and students. Different countries also have different stipulations for what types of healthcare organizations need to be tracked.



For insight on the impact of source data inaccuracies and inconsistencies, we can look to the results of Open Payments reporting.



As cited in Healthcare Data Solutions’ whitepaper, “Open Payments: The Past, Present & Future,” ProPublica reported that 4.4 million records were withheld from publishing by CMS in 2014 due to data inaccuracies. Most of the unpublished records were missing doctor and hospital names, due to manufacturer data inconsistencies and uncertainty.  


Physician Names Missing 56%
Total Value of Missing Data $574M

Source: ProPublica


Additionally, ProPublica reported that 64 percent of the total spending by applicable manufacturers was not attributable to a specific doctor or hospital. Research payments and general payments were particularly problematic:  


Non-Attributable Research Payment Data 90%
Total Value of Non-Attributable Research Data $1.3B
Non-Attributable General Payment Data 31%
Total Value of Non-Attributable General Data $307M

Source: ProPublica


Judging from the high rate of data inaccuracies from Open Payments, it is safe to assume that the same problems will plague manufacturers that are required to comply with transparency regulations abroad.



Fortunately, Concur customers don’t have to look too far for global provider data. Healthcare Data Solutions, the Concur App Center Partner of the Year for three consecutive years (2013-2015), has all the global healthcare data you need for compliance. HDS Global Concur Connect provides instant access to healthcare provider data in 21 countries worldwide. Users can look up healthcare providers abroad, and collect data for aggregate spend reporting, quickly, easily and cost-effectively.



Hear how HDS leverages T&E data to deliver Global Compliance and Transparency Requirements: 



  To learn more about HDS Global Concur Connect, visit Concur App Center or HDS.


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