In preparation of the December 19, 2013, conference call with the VT Attorney General's Office, the Draft Guide to Vermont's Prescribed Products Gift Ban and Disclosure Law for 2014 Disclosures has been posted on the Vermont Attorney General’s website. Among the most noteworthy elements:
CMS released on its website a Submission Mapping Document, upload instructions, schema documents, and sample XML and CSV files. One notable and positive change to the report template is the inclusion of an optional "Home System Payment ID" field. This allows applicable manufacturers to submit to CMS a unique spend transaction ID, which CMS will provide back to the manufacturer if the transfer of value is disputed by the covered recipient. For SpendTracker users, you will be able to use this Home System Payment ID to access immediately all of the relevant information about the transaction, including any allocation calculations and links to source system data, thereby facilitating the review of any disputed data.
You may recall that in September the Vermont Office of the Attorney General ("VT AG") posted 25 enforcement actions related to the state's Prescribed Products Disclosure Law. While 24 of the 25 enforcement actions relate to the failure of the manufacturer to annually report payments and transfers of value provided to health care professionals (“HCPs”), the most interesting enforcement action relates to a manufacturer’s (Novartis Pharmaceuticals Corporation's, or Novartis') violation of the law’s gift ban requirements.
Yesterday, as promised, CMS released the 2014 Teaching Hospital list. This new list provides some helpful format improvements over the 2013 list published in May of this year. Specifically, the 2014 list provides a common name in addition to a legal name – which addresses the problem that one legal name may appear 7 times in the list, each time with a different address, but with identical name entries. So now for 2014, each of the 7 entries will have their own common business name, so they will look like 7 different hospitals with different addresses, that happen to share the same TIN & legal entity. Easier to select (especially if you are unsure of the exact address), and easier to report more accurately.
Starting today (August 1, 2013), applicable manufacturers and applicable group purchasing organizations begin formally collecting financial relationship data for reporting to the Centers for Medicare & Medicaid Services (CMS) under the federal Open Payments (or "Sunshine") law.
Written by: Marc Adler, Esq., Director of Compliance Consulting
Written by: Marc Adler, Esq., Principal & Director of Compliance Consulting
R-Squared is proud to be named as one of Cardinal Health’s “Supplier Success Stories” in their 2012 Supplier Diversity Year End Review. The article provides in part:
R-Squared posed the following question to CMS via the Open Payments website:
CMS hosted a teleconference today covering the final Sunshine regulations. Although comprehensive and overall well done, the content was basic and offered very little new information. Seemingly, and based on the common response to callers' questions, all of the needed clarification will be set forth in an upcoming FAQ document, which is currently undergoing "CMS clearance" and should be available soon. Based on the content of last FAQ, I'm not all that confident that we'll receive the needed clarity on the tougher questions! That said, here's a few quasi-interesting kernels from the call:
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