Reporting and Disclosure

Do you know what you spend on potential referral sources?
California, District of Columbia, Maine, Minnesota, West Virginia, Vermont and numerous other states have enacted or a considering laws that require the periodic reporting of the amount spent on potential referral sources. In addition, the Physician Payments Sunshine Act (expected to be enacted 2008/2009) would require all life science companies (subject to certain limitations) to disclose the amounts paid to physicians through gifts, expenses and other activities. Penalties for noncompliance can be substantial.  

What to report and when?
Most State legislation is inconsistent and whilst the Physician Payments Sunshine Act does give some additional insight into the requirements, it is clear that with most companies operating in multiple States, companies should track the superset of required information. The tracking of all expenses against potential referral sources then not only allows reporting and disclosure as required by each individual State but also helps identify the evidence required to protect an organization from prosecution under the Anti-kickback Statute, False Claims Act and/or other federal legislation; this is the key to Evidence-based Compliance in that a company not only meets the current reporting and disclosure requirements but has all the necessary evidence to demonstrate compliance.

R2: Combining Expert Compliance Knowledge with Leading Technology
R-Squared has combined the compliance knowledge from leading health lawyers and industry organizations with information taken from current and proposed legislation to create SpendTrackerSM, a specialized RADSSM configuration module for the tracking, reporting and disclosure of organizational spend on referral sources. Readily implemented alongside other RADSSM modules, SpendTrackerSM aids the best practice tracking of organizational spend with the minimum impact on existing employees; it allows the reporting of actual and projected spend against both single and grouped referral sources whether by an individual or department at the company.  This information is used not just to meet individual State disclosure requirements but also to allow the business to keep track of overall spend measured against internal guidelines, policies and procedures.