Life Science Compliance Update

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February 14, 2017

Connecticut APRN Reporting Policy Starting to Come to Fruition...Kind Of

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We have previously written about Connecticut policy that was aimed at reporting payments from pharmaceutical and device manufacturers to nurse practitioners. Back when the law was originally passed, Connecticut planned to require pharmaceutical and device manufacturers to report payments and transfers of value to advance practice registered nurses (APRNs), starting July 2015. APRNs include: nurse practitioners, clinical nurse specialists, nurse anesthetists, and nurse midwives. The first reporting date is from July 1, 2015 to June 30, 2017, and requires annual reports on July 1, 2017 (rather than quarterly filings as was in the original legislation).

Under the Connecticut General Statutes, a licensed APRN who has maintained their license for at least three years, and engaged in the performance of advanced practice level nursing activities in collaboration with a physician for at least three years (and at least two thousand hours), may – with or without physician collaboration –

Perform the acts of diagnosis and treatment of alterations in health status and prescribe, dispense and administer medical therapeutics and corrective measures and dispense drugs in the form of professional samples in all settings. Any advanced practice registered nurse electing to practice not in collaboration with a physician shall maintain documentation of having engaged in the performance of advanced practice level nursing activities in collaboration with a physician for a period of not less than three years and not less than two thousand hours.

Companies are required to register and pay a fee.

Any eligible APRNs are required to submit written notice to the Department of Public Health of his or her intention or practice without physician collaboration prior to beginning such a practice. The Department of Public Health is responsible for annually publishing a list of such APRNs who are authorized to practice not in collaboration with a physician, which can be found here.

There are only roughly 450 providers listed who are authorized to practice not in collaboration with a physician. However, the list of providers does not include an address – just the provider name and license number. Such an effort at transparency could lead to unnecessary confusion and uncertainty, on the part of both patients and those trying to keep up with reported payments.  

With no address or much of any identifying information, it could be difficult to be certain that the APRN whose information they are looking at online is the APRN they are seeing. While there are many unique names on the list of APRNs who can practice without physician collaboration, even the most unique names can be shared by multiple people, not to mention many common names.

Further, we have seen the difficulties with the federal Open Payments, and how many payments get attributed to the incorrect physicians, with more information available to them than just a name and license number. Typically, there are hospital affiliations, addresses, etc. that help to identify and confirm physician identities. Even still, there are many payments that are misattributed year after year.

The dates of reporting is also news to applicable manufacturers (GPO's, Distributors, Drug and Device Manufacturers), It is not known why they went back to the July 1, 2015 recording date after the state legislature had delayed reporting.

This move by Connecticut was an expansion of the requirements from under the current Open Payments System; under federal law, APRNs are excluded from the reporting obligations.     

In the interim, keep your eye on Connecticut and other states who are also looking to expand the federal Sunshine Act, as well as moves made by Congress to expand the federal Sunshine Act even further (to be expounded upon in a future article).

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