State Reporting and The Sunshine Act

Passage of the Sunshine Act provisions of the PPACA fundamentally changed the nature of the aggregate spend challenge. While a manual process to fulfill your state reporting obligations was merely inefficient, it will be unworkable in the context of a nation-wide disclosure requirement. Many companies are taking this as an opportunity to re-think their approach and consider both process and systems changes to handle the much larger volume of data to be tracked and reported.

This challenge is made more difficult by the fact that the required data is typically spread across multiple departmental systems, databases and documents. A thorough analysis is required to identify the location of all data related to HCP and HCI transactions as well as any information gaps that would prevent full and complete reporting. As part of this analysis, companies should take into account whether their policies and procedures need to be updated to fill any gaps in data collection, process flows, monitoring and controls.

Even if you already have a strong state reporting solution in place, or have begun to voluntarily disclose some of your HCP-related payments, Parallax can help you get the rest of the way to full Sunshine Act compliance, or perform an independent system and data audit to ensure that your solution is complete and accurate.

A Process-Based Approach

Our methodology begins with a detailed analysis of your company’s current processes, systems and data environment. It is crucial to gain a complete understanding of the existing systems, their relationships to one another and to the business processes that govern HCP interactions before selecting new systems and processes. Our services can be applied to a cross-functional effort that includes your internal stakeholders as well as external partners and vendors.

The methodology is more fully described in our white paper, A Process-Based Approach to Aggregate Spend.

The following provides examples of our services:

• Program Scope and Strategy: Organize the cross-functional team, define the scope, and establish the project goals, phases and timeline.
  
  
• Policy Update: Work with management and counsel to analyze the existing legal and regulatory requirements and develop or update the federal and state-specific reporting policies.
  
  
• Process-Based Assessment: Conduct a review of the existing processes, systems and data environment through interviews with key stakeholders and system walkthroughs.
  
  
• Technology Selection & Solution Design: Work with management and IT to conduct a buy vs. build analysis, evaluate solution options and vendors, and design the future architecture.
  
  
• Implementing New Technology: Manage the implementation of new system components and their integration with existing technologies.
  
  
• Change Management: Manage the rollout of the new processes and systems, including communications, training, and support.
  
  
• Data Validation: We can conduct an independent audit of existing systems for reporting accuracy and completeness.

Contact us to see how we can help your Health Care Compliance needs.

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