Sunshine Act Compliance

Know How

The Sunshine Act: A Tough Act to Follow?

Strategic guidance to help companies comply with the Sunshine Act
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“Progressive companies look to understand the implications of the publicly reported data and leverage the reporting process.”
-- Joanna Sears, Managing Director
The Physician Payments Sunshine Act (Open Payments) requires companies to record any physician payments or benefits provided as of August 1, 2013, and to annually report this information to the Secretary of Health and Human Services (HHS) beginning March 31, 2014.

Acquis helps partners address the Sunshine Act regulations, from performing an overall assessment of their current reporting landscape (including all systems involved) to designing optimal future state processes and systems.

We also help with vendor selection and implementation for companies that require a master list of HCPs/Teaching hospitals, need a hosted technical solution for aggregate spend reporting, or are looking for an expense management system that is Sunshine Act compliant.

Looking towards the future
Many companies have put in place technology or a solution that integrates all of their HCP payments and meets the basic reporting requirements, but several challenges still exist as the data publication date approaches.

We work with companies to address the following questions:

  • How can we decrease the time spent resolving data issues and making sure data is accurate? Can we make the process more efficient?

  • What will our dispute resolution process be and how do we build a process to handle this?

  • How can we generate additional reports that provide valuable insights about our spend activity?

  • What public relations issues might we encounter as data is published, and how can we proactively address these?

Our Approach

At Acquis, every one of our engagements is viewed as a partnership requiring a strong foundation from the very start. We seek to understand first, so your challenges become our challenges and, in turn, opportunities for resolution.

We keep execution in perspective while helping you create strategies and design solutions. We think about sustainable solutions that fit your needs. We work with you to create the clear path to success. We continue to listen to you and your team, but objectively challenge the priorities and identify risks.

Then we roll up our sleeves to do the work. We help you establish the right pace and rhythm while continually tracking and measuring status and progress. We will know when the team needs to adjust to changing business conditions.
At Acquis, we do more than deliver success. In transferring ownership of the solution, we work to elevate and empower your organization with a capacity and ambition for continuous improvement.

We put you and your people first. This is our approach.

Meet the Team

Sunshine Act
Specialists
Managing Director
Joanna
Sears
“Strive not to be a success, but rather to be of value.”
Albert Einstein
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Industry Experience

Consumer Products

Financial Services

Life Sciences

Travel

Engagement Manager
Jeffree
Chan
“Vision without action is merely a dream. Action without vision just passes the time. Vision with action can change the world.”
Joel A. Barker
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Industry Experience

Technology

Life Sciences

Healthcare

Financial Services

Impact Story

Managing T&E Expenses for Sunshine Act

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Managing Compliance: New EudraCT Regulation

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Client Profile
One of the largest pharmaceutical companies in the world
Industry
Life Sciences
Challenge
Travel and entertainment expenditures for one of the world’s largest pharmaceutical companies had exceeded $700 million globally. With that volume of T&E transactions, millions of HCP records, and a project already underway to upgrade the expense application, the mission was to improve expense reporting processes for the US Sunshine Act requirements, design a new solution to meet the France Sunshine Act requirements, and manage the complex priorities of stakeholders, project teams, and vendors.
Approach: Think + Do
To define and prioritize requirements, we consolidated and reviewed US requirements, current pain points, and France’s requirements for the Sunshine Act. We then created a set of design options for the new process and system. After performing analysis to reach an agreement on the best solution for compliance, operations, and users, the transparency strategy and design was complete. From there we set about implementing the solution, managing cross-functional teams from multiple organizations and locations, and managing the change to affected business units and end users.
Results
We successfully provided an updated Sunshine Act compliant T&E solution to two countries with 50,000 employees. The client met all key milestones for the readiness of legal requirements, experiencing no operational problems during the cutover process, which was successfully completed on time and on budget. The overall success of the project led to an invitation for Acquis to participate in the on-going global transparency meetings.
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