Q: Is the industry ready to comply with aggregate spend regs? A: Surprisingly, maybe not.
As a speaker at the CBI Aggregate Spend Conference last week, (with a timely agenda and a great turnout) I was looking forward to gauging Life Science organizations’ response to what will soon be the final regs of the Sunshine Act. I was quickly enlightened. With the first session, I could tell participants were still learning the options for overcoming the challenges of transparency. In fact, some are still in the planning stage!
Knowing the need for information couldn’t be greater, I’ll be hosting a CBI webinar, Healthy Customer Data Is Key to Aggregate Spend Compliance, on September 27, 2011. Register.Listen.Learn.
I listened to a host of perspectives from the distinguished faculty who went before me. Presentations on guidance, legislation, strategy, business operations and data management shed light on the industry’s state of readiness and, by chance, became a compelling lead-in to my presentation, Compliance 2.0: Living with Aggregate Spend.
With my very first slide I asked, “Is the industry ready for Aggregate Spend compliance?” The audience- 85 strong- didn’t seem at all convinced that the industry is ready. I came to a conclusion I didn’t expect when I first arrived, but given the complexity, perhaps I shouldn’t have been surprised. While Life Science organizations are working hard to meet transparency requirements, the industry, with precious few months left until go-time, is not really ready. It’s no wonder that IDC Health called it the most disruptive force affecting pharmaceutical sales and marketing today.
So, what should companies do to start getting ready? The answer for now is much like parental guidance – listen, learn and do your best. Keep working toward your compliance goals. Experts abound on the many facets of compliance. Listen to them. Learn from them. Do your best. And don’t forget that once you’ve checked all the boxes for legal, compliance, business rules, system, and data, you still have the daunting challenge of program governance – the 2.0 of it all. Don’t forget that reports coming out are dependent on the quality going in to your reporting system. Don’t forget the importance of data quality and ongoing management.
- Theresa Greco's blog
- Login to post comments

