Life Science Compliance Update

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May 28, 2013

Physician Payment Sunshine Act: Compliance Recommendations for Physician Practices

Physician Practices
Health IT company RxVantage hosted a webinar with Randy Vogenberg, managing principal at consulting firm Bentelligence, to address some common questions posed by physicians and share best practices, The thirty minute presentation offers several tips: 

  • Educate all of a practice’s licensed providers on the new federal rules, and check on state Sunshine regulations
  • Draft a rep visitation policy to ensure that they are in the office when there are the fewest number of patients, and designate a separate waiting area if possible. That way, patients won’t feel like reps are encroaching on their appointment time
  • Consider having a daily huddle with staff, which serves as a good time to reiterate procedures and ensure the staff knows how to handle visits from sales reps
  • Set a limit for the number of times a rep or company can visit the office within a month or quarter, to ensure you’re getting a rounded perspective and limiting bias
  • Make the most out of rep visits by asking questions and learning about their companies’ patient assistance programs, trials and competitors
  • Keep an easily accessible electronic record of all rep interactions. Providers will have a 60-day window to identify and respond to discrepancies in reported data before it goes public 

These recommendations reflect the valid concern physicians and their attorneys have on this information potentially becoming public and steps to take to reduce criticism.

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