Transparency for FMV Rates: Finding a Balance Abroad

When France first released its 2011 draft of the Bertrand Act — which included a provision similar to the Sunshine Act here in the US – the legislation promised to be more stringent than US guidelines.  The draft required companies to post its payments on its website within 15 days of the activity — complete with the recipient’s name and the amount he or she received.  It also required companies to deliver a report detailing their outside spending to six professional organizations — even if payments were under the US equivalent of $95.  Continue reading


The Sunshine Act is Ready — Is Pharma?

At last.  Cue the Etta James music because the Centers for Medicare and Medicaid Services (CMS) released the final version of the Sunshine Act.  As of February 8, the Sunshine Act will be included in the Federal Register and will go into effect shortly thereafter.  Finally, pharma and the rest of the healthcare industry can breathe a little easier as they shift away from eagerly — or perhaps reluctantly— awaiting further legislative updates to focusing on adhering to these now-finalized guidelines. Continue reading


Four Guideposts to Improve Investigator-Initiated Trials Payment Processes for FMV Compliance


By David Richardson,
Research Team Leader

The Office of the Inspector General at Health and Human Services (OIG) has been highly focused recently on tracking and publicizing pharmaceutical companies’ payments to thought leader physicians and clinical investigators. A number of companies have found themselves under investigation, and some have had to enter into Corporate Integrity Agreements to ensure their practices are up to the scrutiny.

Teams that run investigator-initiated trials (IITs) can play a major part in avoiding (or passing) OIG scrutiny by focusing on improvements in three major areas: Continue reading


Physician Payment Disclosures and FMV Going Strong Despite Sunshine Act Delays


By Elio Evangelista,
Director of Research

The United States is still waiting for the Centers for Medicare and Medicaid Services (CMS) to issue its final ruling on how it will implement the disclosure rules outlined in the Physician Payments Sunshine Act. However, this has not deterred companies from continuing to make public disclosures or caused them to lose focus on determining fair-market value (FMV) physician fee schedules.

Initially, CMS was scheduled to give a ruling to drug and device manufacturers in October 2011. But the agency Continue reading


Fair-Market Value Benchmarking Service Provides KOL Compensation Data for More Than 100 Countries

By Yanis Saradjian,
Director of Consulting

Our newly updated Fair-Market Value Benchmarking and Analysis service now provides medical, scientific and regulatory staff at life sciences companies with fair-market value benchmarks for thought leaders and influential physicians in more than 100 countries. The service is built upon a decade of detailed key opinion leader management research and the Research and Consulting teams’ expertise in FMV benchmarking and developing physician fee schedules. Continue reading


Extended Sunshine Act deadline provides extra time to track and report physician payments

Six Tips to Help Build the Ideal Thought Leader Database

As the industry awaits the release of the delayed Sunshine Act guidelines, pharmaceutical and medical device companies are benefiting from the extra time by reviewing current physician payment reporting structures and tightening their documentation procedures. “Every company, no matter how large or small, needs a tracking and reporting system capable of handling all of the Sunshine Act’s requirements now,” said Elio Evangelista, director of research at Cutting Edge Information. “The largest companiesare ahead of the pack. Most already have sophisticated databases in place, as well as the IT infrastructure and personnel to support the documentation requirements.”

Cutting Edge Information’s report, “KOL Fair-Market Value and Aggregate Spend,” serves as a guidebook to companies working to comply with the reporting requirements of the Physician Payment Sunshine Act while meeting the needs of physicians and internal stakeholders. Based on interviews conducted with medical affairs executives across the industry, Cutting Edge Information recommends the following fundamentals when constructing a KOL database:

  1. Include fields for all information required by the Sunshine Act – Each entry must have fields to enter name, company, Medicare billing number, service provided, physician compensation and other reimbursed expenses (including travel, hotel, and food).
  2. Design strong report-building capabilities – The more sophisticated the database’s query building and report-generating capabilities are, the less work companies will have to do on the back end.
  3. Establish a centralized location – Centrally located databases are more reliable for preventing duplicated efforts and data loss.
  4. Create multiple access points with differing levels of clearance – Some employees may need the ability to enter new information into the database, but not everyone needs to alter information.
  5. Create a built-in system to verify data – It is always easier to handle mistakes internally than to have external agencies point them out.
  6. Include links to, or archive, thought leader deliverables – An easily traceable copy of the thought leader’s deliverable provides undisputable proof that a service has been rendered.

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Physician Salary Data No Longer a Reliable Practice for Calculating FMV

Gone are the days when companies could use a healthcare provider’s annual salary to calculate fair-market value (FMV) for their consulting services, according to the latest findings from our ongoing key opinion leader compensation research. The precision that companies must have when calculating FMV requires an intricate combination of physician qualifications and benchmarking data. Major changes in companies’ FMV calculation methods have impacted the amount of compensation doctors receive. The latest findings Continue reading


Preliminary Work and Travel Costs Take Center Stage in FMV Calculations

New study provides process for calculating compliant fair-market value payments

Although 100 percent of drug companies compensate key opinion leaders (KOLs) for their method of travel, only 60 percent do so for any preliminary work. And as mandatory public reporting of thought leader compensation approaches with the launch of the Sunshine Act, questions remain surrounding both travel and pre-work compensation. Continue reading


Drug and Device Companies Still Waiting For Sunshine Act Guidelines

By Elio Evangelista,
Director of Research

In about five weeks, pharmaceutical, biotechnology and medical device companies will have to start compiling and aggregating data on their physician expenditures to meet the requirements spelled out in the Physician Payments Sunshine Provision of the Patient Protection and Affordable Care Act. There’s a fairly significant problem, however – the U.S. government has yet to provide Continue reading


Investigator Initiated Trials Increasingly Impacted by FMV Concerns

Investigator initiated trial (IIT) management teams must incorporate fair-market value (FMV) into their payment protocols to appropriately respond to regulatory scrutiny and maintain compliance. In our new study, “Investigator Initiated Trial Management,” 23 percent of study participants ranked oversight or intervention from the Office of Inspector General (OIG) as their number one IIT management challenge. Continue reading