The most effective way of ensuring compliance with ever-emerging regulations is to institute controls at the point of contact with the physician – that is, your CRM solution in the hands of your representatives.
Here are four key points to keep in mind as you discuss this with your technology vendors:
The rule covers your organization’s entire expenses for a physician – so if more than one representative calls on the physician you will have to ensure that expenses recorded by each representative are totaled together and shared by all people in contact with the physician. In practice, this also means that you will need to pull expenses from more than one system (for instance, marketing or medical education events) together for reporting purposes. Some CRM solutions allow these expenses to be imported from a 3rd party system and matched to physicians in the CRM database using a match key such as an ME number, State License Number or DEA number. This approach has the advantage of bringing the information together in a single place (thereby reducing the proliferation of systems), and brings the added benefit of giving the field sales organization visibility into the value of the complete investment in a physician. True CRM systems also have the capability to provide a platform for the marketing and CME departments, so sales, marketing and event management can be consolidated on a single platform.
For ease of entry, users should not have to enter a separate expense for items that are already being recorded – for instance, if the representative is already recording a leave behind, that amount should be automatically calculated and added as an expense. The user should not have to add it twice. Expenses should also be categorized by type, for instance sample costs should be categorized for easy reporting. Some states will require reporting of marketing expenses for instance, but not sample values, so for compliance reasons the database should be as complete as possible.
Expenses, such as lunch, provided for an entire practice should be divided automatically among the physicians at the practice, or the system should allow the user to easily mark off the physicians that were in attendance. Ease-of-use is an important factor to ensure accuracy of this data. So that users are not simply recording all the expense against the doctor at the top of the list, the form should encourage the user to check of a suggested list of attending physicians. There should also be the ability to record the number of non-physician attendees, as there may be some situations where expenses for the office staff are not required to be reported to a physician.
It may be wise to keep physician expense reporting separate from your expense reimbursement systems because your expense reimbursement systems are unlikely to track leave behinds or other non-reimbursable expenses that must be tracked and reported for compliance purposes.
Get Some Business Benefit
Compliance with mandates does not preclude real business benefits. We recommend that you review field management reports for opportunities to add value with this information – for instance, a reach and frequency report could include the added dimension of expense ratios by decile or other targeting mechanism. We also recommend that this becomes another input into your targeting mechanisms – for example, StayinFront’s Ranking Engine can take scripts, calls, samples and expenses into account when answering the question: “who is a customer?”
Early Warning Systems
The latest CRM solutions include engines that check the database for data that pass thresholds and send alerts or reports based on those thresholds. For instance, a CRM system with a robust workflow engine can track expenses against physicians and send alerts either through the CRM system or through email as those expenses cross-predefined thresholds – and escalate those expenses that are in excess of allowable limits. These kinds of automated processes are key to compliance activities as they have the potential to stop an issue before it becomes a compliance issue by alerting the correct people before the threshold or limit is reached. Previous generations of systems relied on reports after the fact, but by then, it is too late as there has already been a breach of company policy or governmental regulation.
While compliance requirements frequently mean it’s time to identify yet another software product to ensure the visibility required for reporting, that’s not always the case. Check your CRM system vendor to understand how your CRM investment can be leveraged for expense tracking.
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By Sam Barclay, Vice President of Business Development for StayinFront, Inc. and Ken Arbadji, Vice President of North American Sales for StayinFront, Inc.
