Life Science Compliance Update

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January 17, 2018

Nevada Posts FAQ and Reporting Requirements on Transparency Law

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As we posted last week, the Nevada draft regulations are up and starting to become a hot topic. The same day as our last post, Nevada updated the Frequently Asked Questions and the SB 539 Reporting requirements.  

Frequently Asked Questions

The two-page FAQ document provides some helpful answers to common questions, such as whether the reporting for pharmaceutical representatives is the responsibility of the individual or of the manufacturer. Nevada notes that it is the responsibility of both and then lists specific requirements. For example, manufacturers are required to submit a list of names of all pharmaceutical representatives who market prescription drugs in Nevada while each pharmaceutical representative is required to submit a report of all compensation or prescription drug that was provided to a provider of health care that is licensed, certified, or registered in this State, among others.

The FAQ also confirms that the law applies equally to all pharmaceutical representatives and not just those who are engaging in the sales and marketing of the diabetes-related treatments state on the website.

The FAQ also includes links to report formatting and other specifics for prescription drug manufacturers and pharmacy benefit managers.

Reporting Requirements

Drug Manufacturers

As required under the law, prescription manufacturers must submit a report to the Nevada Department of Health and Human Services (DHHS) with the below information, for prescription drugs posted on the DHHS website. This report must be submitted via email annually by April 1st of each year for the previous calendar year. DHHS then compiles a report and posts it in accordance with NRS 439.

Manufacturer requirements

Pharmacy Benefit Managers

PBMs are also required to submit a report to DHHS by April 1st of each year. The required information for that report is as follows.

PBM

Pharmaceutical Sales Representatives

Pharmaceutical sales reps that are on a list submitted to DHHS by drug manufacturers anytime during the previous calendar year must submit their report by March 1st of the year, including the below items.

Pharma Rep

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