By now, most of us on the planning side are aware of the sweeping changes that took place in the management of medical meetings since the passage of the Physician Payments Sunshine Act (PPSA), aka “The Sunshine Act.” Since 2009, small steps have been taken to put guidelines in place for enforcement, but as of August 2013, it got serious. That was the start date for the first reporting period of all gifts and payments greater than $10 made to physicians and hospitals by pharmaceutical and medical device manufacturers.
What does this mean to planners? Well, for starters, now we’ve all become compliance monitors, right? But do you even know what that means? Because there are so many terms thrown around at each medical meeting we manage, I thought it might be beneficial to provide a brief cheat sheet of frequently used terminology that we are now seeing on our paperwork. Think of this as your “Cliff’s Notes” version of compliance communications! So here goes:
Physician Payments Sunshine Act (PPSA). The PPSA officially began in August 2013. In its simplest form, PPSA is meant to discourage improper influences by the pharmaceutical and medical manufacturing industry over research activities that could compromise the integrity of patient health care. Think of this as the pharmaceutical industry policing themselves in lieu of the government taking over this job.
Centers for Medicare and Medicaid Services (CMS). As the repository for all the medical reports that are now being generated, CMS is responsible for public postings.
Compliance and Compliance Officers. In its simplest form, compliance means obeying the guidelines set forth by the PPSA. Compliance Officers, normally hired by each pharmaceutical company or by an outside source (think auditors), are charged with making sure each program they attend is meeting the standards and guidelines as outlined in the PPSA. Note: As a GCG planner, I have already encountered numerous compliance officers in meetings that I have managed, so be aware that they are definitely out there and watching!
Health Care Professional (HCP). It is important that you understand who qualifies as an HCP because many of the programs we are asked to monitor as a member of the GCG network are to be attended only by qualified HCPs. As planners, we see a wide variety of initials and acronyms behind people’s names as they check in for these events, so make sure you ask questions if you run across one that you’re not familiar with. In general, physicians (MD’s of any kind) are allowed into these programs. However, sometimes HCP’s such as registered nurses (RNs) and Physician Assistants (PAs) do not qualify, so make sure you review the particulars given to you with each program. Finally, you should also note that a PhD behind a person’s name does not automatically make them a medical HCP.
Transparency. As used in the context of medical science implies openness, communication, and accountability. In other words, no hidden costs or elements to what is being presented, served, or given to HCPs.
Transfers of Value (TOV). For the purposes of this discussion, think of this as the situation where an HCP shows up at a dinner meeting and actually eats the meal or drinks the beverages provided. The act of eating/drinking is completing a TOV in regards to the price/value of the meal consumed. It can also refer to a coffee break consumed at a pharmaceutical-sponsored medical meeting, a logo-printed ink pen given to attendees, and much more. Whatever the item, it has a value that must be reported.
National Provider Identifier (NPI). All physicians have one, but not all HCPs. It is now required that they list it alongside their name on sign in sheets so that the TOV can be reported to the correct NPI. In lay terms, you can think of this like your individual income tax. Done each year, your social security number is a unique identifier that allows you to report your earnings/expenditures to the government. The NPI number is similarly unique, and required for necessary accountability in medical reporting.
Office of Inspector General (OIG). This is where the “out of compliance issues” will end up, so you do not want to have your records turned over to this office!
Department of Justice (DOJ). Again, like the OIG, you do not want to be involved at this level!
Continuing Medical Education (CME). CME credits (or units) are given to many HCPs upon attending meetings that meet certain criteria. It’s important to know that not all medical meetings award CMEs.
Open Payments. This website is where all the reporting to the CMS is being maintained. Once listed, all physicians can log on (using their NPI) to see exactly what has been reported against their account per reporting period. In the end, this information must also jive with what the individual is reporting on their own personal income tax at end of year.
Fair Market Value (FMV). The FMV is the cost for a product or service (e.g., dinner, speaking honorarium, travel expenses, etc.) that is being reported, and is based on either precedent or extrapolation.
So, now it’s all clear as mud, right? We thought so.
The big takeaway from all of this is that meeting planners at all levels, not just those employed on a full time basis by a pharmaceutical and/or medical education or device company, are being held accountable on many levels to the PPSA. This even translates down to us, as On-Site Meeting Managers. You can fear it, meaning potentially turn away from this type of business due to lack of knowledge, or you can embrace it, meaning accept that you are a part of a new system that will require education and patience mixed with an expected learning curve.
Terry Matthews-Lombardo is an industry veteran meeting planner, trip director, and free-lance writer who’s seen and experienced a lot of challenges – the good, bad, great and ugly – during her professional lifetime spent in this industry. Based in Orlando, FL, she’s been a proud and active member of the GCG Network of planners since 2005. You can read more by Terry on her blog Hospitality Hive.