By now, pharma and device companies have reported their aggregate physician payment data to CMS. Firms are now gearing up for the next phase: detailed filing of Sunshine data later this year, after which the inquiries and disputes window will begin.
That has companies worried—are call centers and sales reps equipped to handle inquiries? Where will they go to track down information, should a physician dispute payments for an educational item or a meal? These queries could come pouring in, threatening to swamp companies’ transparency staff.
This year CMS changed its timeline to a two-step filing process: the aggregate data (by March 31) followed by a granular filing and 45-day CMS inquiry and dispute period. While there is still some time left before the next filing, consultants from Huron Consulting Group said, many of the consultancy’s clients are thinking about how to smooth out some of that anticipated work.
One of the consultants, speaking on an April webinar, recalled that a client mentioned how he had gotten an inquiry from a physician about a sandwich. “It took him a week…on and off…to resolve this inquiry about one sandwich,” said Joseph Morrell, a manager in Huron’s life science practice during a webinar.
Typically, companies’ aggregate-spend teams have assigned only one or two people to handle disputes, according to a survey Huron conducted among 38 life science companies. “A lot of our clients are trying to figure out how many disputes they might get,” said Morrell. “Nobody really knows.”
One way to prepare: make transaction data available for HCPs to review before CMS’s review period. A small pre-disclosure pilot can be used to “pressure test” the process for handling inquiries and disputes, Morrell said. A third of respondents have done some sort of pre-disclosure this year, survey data indicate.
Clients are also thinking about where will they go to track and identify “dispute themes,” and equipping field teams to handle FAQs, while trying to keep sales reps out of the process.
Three-fifths of respondents (59%) said they want minimal rep involvement in the dispute process. “A lot of our clients worry a physician might make a dispute with a sales rep, and the rep would forget some of the information, or not write it down correctly; and it wouldn’t get into the aggregate spend system,” said Morrell.
Instead, many clients are getting a list together of destinations to which doctors could send their questions, like a help desk, AE-reporting area or customer service line, and equipping these call centers with key talking points around open payments.
And, Morrell noted, some are already considering doing a pre-disclosure in the fourth quarter, for data from the first half of this year, after the CMS window for 2013 data closes.
They are building the list of whom to include on such pre-disclosure lists: either tracking all those who disputed a transaction this year and automatically sending it to them; or sending data only to those HCPs who logged the most transactions or highest dollar amount, for instance.
While only 30% chose to pre-disclose this year, Morrell said, “I think it will be quite a lot higher going forward.”