Top 10 Common Transparency Mistakes
…that MedPro Systems can help fix!

Incomplete or Manual Spend Data Capture

1) Travel & Expense (T&E) Configuration
Not properly configuring the T&E solution to accurately capture precise
Healthcare Provider (HCP) details during spend entry, and instead relying
on manual entry (e.g., use of “business guests”) or leveraging “favorites” lists,
leading to significant HCP identification and matching issues when preparing

2) Accounts Payable (AP) Configuration
AP system doesn’t support identifying reportable recipients and capturing all
required HCP and Healthcare Organization (HCO) details, necessitating manual
data entry and bottlenecking report generation.

3) Transfers of Value (ToV) Itemization
Spend data is provided as total spend to a recipient, in Accounts Payable or
from third parties. For example, there is only one line item for an HCP who
attended an advisory board that includes meals, travel and a consulting fee.
Creating detailed spend required for reporting is a manual and time-consuming

4) Transfers of Value (ToV) Product Details
Transfers of Value are not connected to a marketed product(s) as the spend
is captured, requiring a product to be connected to the spend later, prior to

5) Location Details
Spend records don’t include the city and state (destination) of the related
transaction(s) for travel.

6) HCP Cross Reference
HCP profile data or spend details do not identify when multiple State Licenses
are held by the same HCP, potentially leading to noncompliance with State
reporting obligations or gift bans.

Gaps in Transparency Program Architecture

7) Flexibility to Changes
The rules continue to change. Failure to track regulatory changes and evolve
data collection and reporting processes creates risk of non-compliance with
reporting requirements.

8) Product Identifiers
Failure to define all required values in a reasonable time in advance of reporting,
including but not limited to Device Identifier (DI) for medical devices and
National Drug Code (NDC) for pharmaceutical products, respectively, creates
delays at reporting time.

Missing Compliance Program Considerations

9) Data Audits
Knowledge is power, and there is a tremendous amount of intelligence in data
captured for transparency reporting. Not leveraging this data for auditing and
monitoring beyond transparency creates a risk of missing compliance red flags
and opportunities for compliance program enhancement.

10) CMS Registration
Procrastination can lead to scrambling, like failing to register all required roles
with CMS in sufficient time before the Federal Open Payments (Sunshine Act)
reporting deadline.

We’ve seen it all and we’re here to help!

Whether you are looking for guidance on the rules, benchmarking & best practices,
or simply need help getting it all done, MedPro is your trusted partner.

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