As the deadline for CMS Open Payments reports submission draws close, we ought to share 4 of the common mistakes that happen during Federal Sunshine Act reporting. And how you should be avoiding them.
Before we begin, let’s keep in mind that two types of errors could potentially come with spend transparency:
- Technical errors
- Compliance violations
Technical Errors:
are mostly formatting errors due to which the CMS Open Payments portal may stop you from report submission and ask you to rectify them. Not really a big problem, but it gets annoying to be flagged with an error that bars your submission, right?
Compliance Violations:
are a slippery slope. The CMS portal won’t flag errors for these violations, but it can land your company in trouble. Compliance violations make your company vulnerable to scrutiny, so these require special care.
In this blog, we’ll cover 4 most common technical and compliance violations that you should avoid:
1. Duplication of transactions
Keep an eye on duplicate transactions to avoid over-reporting. Identify such transactions by cross-checking the HCP’s name, date/time, and transaction amount.
2. Selection of Calendar Year
Most companies over or under-report their expenses because they either report transactions exceeding January to December of the year or miss out on some transactions during the year. That’s why it’s very important to compile and report all transactions for a period of January of the year to December of the same year.
Ever noticed December is a whole lot different holiday mood? Most of your sales reps might be in that mood, too, until they return from holidays in January. This is why some of the transactions from the last few days in December before the holidays might be reflected in your systems by January of the upcoming year. Make sure you check those late entries, too, while compiling reports.
3. Foreign Currency Exchange
Not sure if you have come across how one of our clients had a compliance nightmare because of a glitch in her previous reporting tool that reported 850 Czech Krona as 850 US Dollars. But foreign currency exchange leaves you most vulnerable, make sure you check all currency conversions in your reports.
4. Negative or 0$ Transactions
If you’re using expense management tools like Concur, you must be familiar with negative transactions in case of editing a record. Likewise, sometimes you don’t get HCPs’ consent, and transactions have to be reported as 0$, right? One common mistake is people miss out on negative transactions or report too many 0$ transactions. CMS prescribes as little as possible 0$ transactions, but a negative transaction is a complete no-no. You must make sure you balance out all negative transactions.
So, these are the 5 most common mistakes made during the Physician Payment Sunshine Act reporting cycle and some remedial tips on how to avoid them.
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