Accuracy and completeness are the ultimate objectives of transparency reporting and the primary dimensions by which data quality is measured in the aggregate spend arena. With unlimited resources and unlimited time, this objective could easily be attained by most organizations; but in the transparency reporting game, the limiting factor is time.
Each jurisdiction that requires transparency reporting has a submission deadline. In most cases, failure to meet these deadlines results in financial penalties, in addition to the public relations impact -- the consequences of being a delinquent reporter. Because of the manufacturers’ time constraints, 100 percent accuracy and completeness is, at best, an asymptote to an organization’s data quality metric.
However, with the CMS delay in a final Physician Payments Sunshine Act rule, applicable manufacturers are in an advantageous position to address accuracy requirements. How? By incrementally improving promotional spend data quality.
Consider the lifecycle of a promotional spend transaction (inception to final posting), it can be driven by one of two groups of activities: upstream and downstream processes.
Upstream processing activities manage data and provide transparency controls before or at the point of spend entry. These processes include source and reporting system governance as well as top-down policies and procedures. This approach adds a level of control around the data entered into transactional or process-based collection systems.
Downstream processes are defined by data management processes that occur after spend activities and data capture. These processes include the use of customer and product MDM hubs and data remediation processes to manage quality.
On general inspection, it would seem logical that upstream processes have significant advantages over downstream processes. While in general that may be true, there are subtleties to each approach that require consideration as companies look at ways to tighten data and process governance while CMS works on publishing a final rule.
On April 16 at 2:55 pm, my colleague, Greg Maynard, and I will be presenting these approaches, in depth, at CBI's 3rd West Coast Forum on Sunshine, State Laws and Aggregate Spend. After the forum, I will update you on the various points that characterize the upstream and downstream data management approaches.