US State and Local Aggregate Spend Reporting Requirements

Overview

As part of the continued effort to further expand transparency into the financial relationships between Healthcare Professionals (HCPs) and Healthcare Organizations (HCOs) and medical product manufacturers, various cities, counties, and states (also known as “jurisdictions”) have enacted legislation that requires the disclosure of data related to these relationships. Depending on the jurisdiction’s requirements, Life Sciences companies must report certain interactions, payments, transfers of value, and/or product samples provided to HCPs and HCOs. These jurisdictions also have different reporting deadlines:

• Nevada: March 1^st
• Vermont: April 1^st
• Minnesota: May 1^st
• Connecticut: July 1^st
• District of Columbia: July 1^st
• Miami-Dade County (FL): July 1^st
• Massachusetts: July 1^st
• Chicago (IL): No later than 30 days after the department requests it
• California: Company-defined deadline

Pharmaceutical manufacturers must report on payments made to HCPs and HCOs for travel, research, gifts, speaking engagements, meals, entertainment, education, and other purposes. Additionally, some jurisdictions require reporting on product samples, vouchers, and coupons provided to HCPs. In some instances, pharmaceutical manufacturers must register with the jurisdiction or inform them that a report will be submitted, collect data for the specified reporting period related to these expenditures, format the data according to jurisdictional requirements, and submit the report by that jurisdiction’s deadline.

Resources

• For more information on California’s requirements, visit:
  http://www.leginfo.ca.gov/pub/03-04/bill/sen/sb_1751-1800/sb_1765_bill_20040930_chaptered.pdf
• For more information on Chicago’s requirements, visit:
  https://www.cityofchicago.org/city/en/depts/cdph/provdrs/healthy_living/svcs/pharmaceutical-representative-license.html
• For more information on Connecticut’s requirements, visit:
  http://www.portal.ct.gov/DCP/Drug-Control-Division/Drug-Control/Expenditure-Disclosure-Form
• For more information on D.C.’s requirements, visit:
  https://dchealth.dc.gov/node/158762
• For more information on Miami-Dade County (FL)’s requirements, visit:
  https://www8.miamidade.gov/Apps/COB/LobbyistOnline/Views/General/Lobbyist_AboutSite.aspx?topic=main_expreport
• For more information on Massachusetts’s requirements, visit:
  https://www.mass.gov/how-to/submit-disclosure-reports-for-the-pharmaceutical-code-of-conduct
• For more information on Minnesota’s requirements, visit:
  https://mn.gov/boards/pharmacy/resourcesfaqs/paymentstopractitioners.jsp
• For more information on Nevada’s requirements, visit:
  http://dhhs.nv.gov/HCPWD/DRUG_TRANSPARENCY/
• For more information on Vermont’s requirements, visit:
  http://ago.vermont.gov/disclosures-manufacturers-prescription-drugs-biological-products-medical-devices/

How MedPro Systems Can Help:

Streamline Federal Open Payments (Sunshine Act), State, Local, and International Aggregate Spend data capture and reporting with MedPro’s suite of transparency solutions and integrated advisory services:

• MedPro ComplianceReportingID – The complete end-to-end transparency reporting solution
• MedPro Compliance Advisory Services – Tailored support to establish, maintain, and optimize effective compliance and transparency programs
• MedPro Concur Connect – Capture all required HCP data attributes in SAP Concur to meet Federal Open Payments (including the newly required NPPs dataset), State, and Local requirements
• RegulatoryID – Stay informed on new and evolving regulations with our authoritative Federal, State, and International transparency resource library.