November 14, 2019

Life science organizations account for a number of variables when deciding on an accurate FMV payment for contracted HCPs.  It’s a process that — at some point — involves confirming the title of an HCP in the context of a company’s engagement.

A key factor in verifying a doctor’s title for FMV purposes stems from their personal career development.  Accomplished HCPs often hold multiple titles at the same time or move from one position to another in a short span of time.  For example:

  • Specialist doctors within hospitals — e.g., neurologists, cardiologists, hematologists — can also hold the title of medical director or other general, high-ranking positions. Depending on their need, companies that encounter this scenario decide on whether they will contract the HCP as a specialist or as medical director.
  • On a similar note, a prospective HCP may have different titles over a short period of time. This typically takes place within the same therapeutic area or title — think of a registered nurse who becomes a nurse practitioner (NP) or a pharmacist that becomes a hospital pharmacy manager.

Policies that address FMV compensation often provide instructions for determining HCP title.  A common guideline is setting a time limit for an HCP with multiple, former titles.  Like an expiration date, some policies may recommend against contracting a title if the doctor associated with it hasn’t worked in that role for a set number of years.

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Todd Middleton is a senior research analyst at Cutting Edge Information. In this position, he provides qualitative FMV information for in-house and external use to ensure compliant HCP engagements. As an analyst, Mr. Middleton affirms that accurate data, in combination with topical research, can ensure successful life science company compliance. He is a graduate of the College of Charleston.