The industry has effectively used technology for decades in every facet of the business. From enterprise resource management to CRM platforms, technology has been an integral part of the industry’s expansion and growth; however, many compliance departments lag in adopting systems to manage their compliance programs. For example, many organizations continue to use manual processes, like Word forms, Excel spreadsheets or their contract management systems to manage healthcare professional (HCP) engagements. These manual processes usually fail to incorporate all of the necessary elements needed to apply effective controls in this area. As Mark Farrar, life sciences governance, risk management and compliance partner at Guidehouse, wisely stated: “Companies may have developed robust compliance programs, but if they can’t prove they have the appropriate controls and review processes in place (i.e. they have to be documented), then it calls into question the legitimacy of the specific activity.”
Fortunately, the need to implement systems to comply with transparency requirements all over the world has helped to introduce the benefits of implementing more technology solutions in this space, and the tide is shifting. According to Mark Linver, managing director at Deloitte: “Our team recently conducted an industry survey where we asked organizations with partial to no automation if they were planning to implement an automated end-to-end HCP engagement process in the future. 53% of the companies we surveyed stated that they intended to automate within the next four years.”
An effective technology solution to mitigate the risks associated with HCP engagements should:
- Create a centralized process for needs assessment/event justification review and approval that empowers the business to manage their HCP engagement risks
- Capture evidence of the HCP screening and approval process
- Ensure approved compensation/fair market value (FMV) rates are applied consistently throughout the organization
- Provide a platform that easily integrates with an organization’s current contract management system
- Incorporate payment controls to avoid exceeding approved hours, rates and/or FMV limits
- Provide a system to proactively monitor and audit HCP engagement data to detect potential compliance issues
- Act as a repository for HCP engagement document retention.
Staying ahead of the risk curve and complying with global regulations requires appropriate controls and review processes. If you are interested in learning more, click here to download our white paper Managing the Complexities of HCP Engagements.