Yes, it’s tax time again. And if you lose sleep just thinking about a potential audit of your own personal income because you might possibly have stretched the truth just a teensy bit about some business deductions you made last year … well, consider yourself lucky you’re not a meeting planner for one of the big pharmaceutical companies. It’s possible they’re all sleep deprived now that the Physician Payment Sunshine Act (PPSA) has taken effect. Thanks to PPSA, a key part of the federal Affordable Care Act of 2010, meeting planners and on site managers can now be held accountable for both the information we gather at our meetings and the accuracy of the final submission of those reports.
What does this mean to me?
As a member of the GCG network, it’s pretty much a given that you’ve worked some pharmaceutical meetings; and for those of us who’ve been at this a long time, “Oh, the changes we’ve seen!” To the point, it’s no longer good enough that we capture barely readable contact information from our program attendees. You know, the doctors that don’t like taking the time to sign their name on your registration forms? Well, the requirement for accuracy and compliance in whatever format is requested per client program is our new mantra, and rather than fight the new systems you’d best jump on the PPSA train as fast as possible to avoid being run over by it. Simply put, now more than ever before as a GCG On-Site Manager (OSM), it’s your responsibility to pay attention to those pesky details that may seem ridiculous but in fact are the law: PPSA law. And, like it or not, it’s here to stay.
What do I need to know?
There are lots of information networks where you can read up on details to better understand exactly what the PPSA law is, but in a nutshell what it’s all about is compliance between what services or goods (think dinner programs, product theaters with swag bags, etc.) a physician or health care professional (HCP) has openly and willingly received (thus the need for signatures) as distributed by a pharmaceutical company. Of course as with all things that the federal government has a hand in, there are plenty of twists and turns and addendums to complicate an already complicated procedure.
Thankfully, no one has required that we memorize the details. Whew! However, that doesn’t relieve us from the responsibilities that we do accept with each program we agree to work. Those details include but are not limited to:
- Verifying that every attendee we accept into a program we are managing is an HCP
- Obtaining accurate and legible sign in confirmation from each qualified HCP
The rest of the details in each of our assignments are up to the individual pharmaceutical company that is sponsoring the program. But you should be keenly aware that details will vary with each client depending on a number of factors, so it’s best if you don’t assume they all need the same thing, and it’s up to you to pay close attention to whatever instructions have been given to you for each particular assignment.
Yes, it is a federally-mandated law that all must comply with, but it’s up to each individual company as to how they interpret this law as it applies to each and every event they sponsor or host. And as an OSM for GCG is your professional obligation to make sure you follow those instructions down to the last, legible letter.