For many of us in the healthcare industry, the advent of the Physician Payment Sunshine Act has loomed large and ominous. The mere mention conjures up visions of significant changes in the way we work with healthcare providers (HCPs), in addition to endless data collection and reporting. On March 31, 2014, healthcare manufacturers are required to submit their first annual federal reports; these reports will include data captured from August 1, 2013, through December 31, 2013. By September 30, 2014, CMS will publically disclose the information on their website. This regulation is associated with the Affordable Care Act, and as we have come to learn, there may be changes, revisions, or postponements to current guidance on reporting and timing of data review and corrections. Nevertheless, the industry needs to be prepared and many of our clients have been adapting for some time.
So to date, do we really know how this regulation will transform our corner of the healthcare geography? Are we prepared to adapt and innovate?
From a medical education and scientific publication perspective, we have already seen substantial changes in the way our clients collaborate with HCPs. For example, in December of 2013, GSK announced that the company will begin a process that will effectively stop direct payments to HCPs for speaking engagements and for attendance at medical conferences. To fill this gap, it appears the company may expand its focus on developing multichannel capability to support the dissemination of information about its products and relevant disease states to healthcare professionals.
The effects of the Sunshine Act are also noticeable in the scientific publication realm. Due to the transparency requirements, academic research institutions are once again modifying their guidelines and tightening their restrictions on working with industry on clinical trials and subsequent data publication to avoid the perception of and potential for conflicts of interest. These restrictions also pertain to the development of disease-state articles that update standards of care and provide best practice approaches for HCPs and allied health professionals.
Clearly the Sunshine Act is meant to shine the light of transparency and public disclosure. But it also has the potential to hamper scientific exchange, which is the lifeblood of effective medical communications.
How do we as an industry respond? My vote is to adapt along with our clients and lead and encourage the innovation and continued delivery of robust scientific exchange. How will you respond?
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