Physician Payment Sunshine Act: Physicians and …...2 Physician Payment Sunshine Act Survey methodology and major findings The survey of 110 U.S.-based physicians and 223 executives

Physician Payment Sunshine Act:Physicians and life sciences companies coming to terms with transparency?

Physician Payment Sunshine Act 1

Calls for more transparency and disclosure of payments made by the life sciences industry to health care professionals are creating challenges and opportunities for all parties involved in the delivery of health care. A recent case in point is the Physician Payment Sunshine Act (PPSA), part of the Patient Protection and Affordable Care Act (ACA). This proposed rule from the Centers for Medicare and Medicaid Services (CMS) “would require applicable manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid or the Children’s Health Insurance Program (CHIP) to report annually to the Secretary [of Health and Human Services] certain payments or transfers of value provided to physicians or teaching hospitals (‘covered recipients’). In addition, applicable manufacturers and applicable group purchasing organizations (GPOs) are required to report annually certain physician ownership or investment interests.”1

Under PPSA, the first reports will be due March 31, 2013, for the calendar year 2012 reporting period, and must include information about the amount of the payment, the date on which it was made, the form of payment, and the nature of the payment (e.g., gift, consulting fees, or entertainment). ACA provides that violators of the reporting requirements will be subject to civil monetary penalties (CMPs), capped at $150,000 annually for failing to report, and $1,000,000 for knowingly failing to report.2

The Congressional goal of PPSA was not to eliminate financial interactions between life sciences companies and individual health care providers (HCP), but rather to empower patients by providing visibility to those interactions. The hope was that by providing such visibility, patients could question whether the financial interactions might negatively affect their course of treatment.

1 https://s3.amazonaws.com/public-inspection.federalregister.gov/2011-32244.pdf. Accessed April 10, 2012.

2 http://www.cms.hhs.gov/apps/media/press/release.asp?Counter=4220. Accessed April 10, 2012.

Results from an early 2012 survey of physicians and life sciences executives conducted for Deloitte Touche Tohmatsu Limited (Deloitte) by Forbes Insights (see Methodology) indicate that both parties appear to be coming to terms with the concept of transparency, and that health care providers and life sciences companies expect to continue collaborating to develop new and more effective treatments for patients. Physicians do have concerns over how the data will be interpreted by the public (e.g., the context), as well as their own understanding of the requirements of the new regulatory environment. Dr. Genevieve Fairbrother, chief of medical and dental staff at Northside Hospital in Atlanta, summarizes the issue: “Knowledge is power; incomplete knowledge of what this kind of data is really saying will lead to misrepresentations. In a properly framed context, nobody would have a problem with it.”

Life sciences company executives, on the other hand, at this time are less focused on the public’s interpretation of the data than the logistics of aggregating and reporting it. As a result, most are still investigating how best to leverage the data for competitive advantage once it becomes publicly available.

2 Physician Payment Sunshine Act

Survey methodology and major findingsThe survey of 110 U.S.-based physicians and 223 executives from life sciences companies worldwide was conducted for Deloitte by Forbes Insights in January-February 2012. Among physicians, the biggest group (28%) was comprised of family medicine and general practice doctors. Among the life sciences executives, 47% came from North America, 36% from Europe and the United Kingdom, and the rest from Asia, South America, and the Middle East. Company revenues ranged from $500 million to $20 billion-plus.

Among key survey findings:• PPSAandothernewregulationsarerequiringlife

sciences companies to make significant infrastructure and compliance program investments.

• Despitethenewreportingrequirements,neitherphysicians nor life sciences companies plan to significantly change the way they currently interact.

• Givenhowphysicianssaytheylearn,theremaybeopportunities for the life sciences industry to alter where it expends financial resources; this, in turn, may reduce the issues/objections to health care provider financial interactions.

• Whileamajorityofphysicianssurveyedacknowledgesome financial interactions with the life sciences industry, most do not believe it is material to their overall income.

Physicians’ views Attitudes towards disclosureMore than two-thirds of doctors surveyed support the idea of a public, searchable database of all doctor-industry relationships (Figure 1); however, the majority of them do so with the caveat that they are in favor of the database as long as patients understand how to interpret the data. Twenty-seven percent of doctors believe that such a database constitutes an invasion of doctor privacy.

Figure 1: Are you in favor of a public, searchable database of all physician-industry relationships to be available to the public?

Figure 1: Are you in favor of a public, searchable database of all physician-industry relationships to be available to the public?

Yes, as long as patients understand how to interpret the data

No, such a database is an invasion of doctors' privacy

Yes, the more information patients can get, the better

Other

14%

27%

54%

5%

David J. Rothman, Ph.D., director of the Center for the Study of Society and Medicine at Columbia University and a proponent of disclosure, is skeptical that consumers will use the data in selecting a physician or question their physician about the data. “There are lots of databases out there that, for the most part, patients don’t use. Maybe the next generation of patients will use it, but I wouldn’t expect any major use by patients now,” he says.

Current physician/life sciences industry relationshipThe relationship between doctors and the life sciences industry consists mostly of doctors accepting free samples, detailing by sales representatives, and doctors attending industry-sponsored seminars. Over half of the responding doctors said they have these types of relationships, with the largest group of doctors (65%) saying that they accept free samples (Figure 2). Physicians also consider industry-sponsored seminars, detailing, and free samples to be the best means for learning about new medications and treatments, with the largest group (57%) pointing to industry-sponsored continuing medical education (CME) seminars as the most effective for learning (Figure 3).


One surprising outcome from the study is an apparent disconnect between how physicians say they learn and what the life sciences industry thinks is the most effective way to provide information to them. As noted above, physicians feel that CME is the most effective learning tool, while industry executives believe their most effective marketing tool is free samples. The results also suggest that both detailing and consulting and speaking fees are of lesser importance to physicians than the industry believes. All of this suggests that the data from transparency may present some interesting and useful insights for both physicians and life science industry. Figure 4 outlines the results.

Figure 2: Which of the following describes your current relationship with the pharmaceutical industry? (Respondents were asked to select all answers that applied)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.90000253.60000260.300003

I accept free samples65%

58%

52%

35%

16%

12%

8%

Detailing by sales representatives

I attend industry-sponsored continuing medical education seminars

I accept food, entertainment and travel

I accept consulting and speaking fees

Other

I accept research grants

Figure 3: Which of the following do you find most effective in terms of learning about and prescribing/ordering new medications and novel treatments? (Respondents were asked to select top three areas)

Industry-sponsored CME seminars57%

52%

42%

20%

12%

5%

3%


Free samples

Other

Food, entertainment and travel

Consulting and speaking fees

Research grants


Most doctors believe that they do not derive material income from their relationship with the life sciences industry. Of the 30% of doctors who said they do derive some income from the relationship, a vast majority reported that less than 1% of their income comes from the industry, while 7% of all doctors surveyed put the share of their income derived from the industry at 1% to 10% (Figure 5).

Understanding PPSA and future relationships with the life sciences industry Despite the continuing financial interactions between physicians and life sciences companies, most physicians (85%) seem to understand what constitutes a conflict of interest under existing regulations; almost half of the doctors surveyed said that the pre-2012 regulatory environment led to ethics breaches. As a result, the majority (64%) said that disclosure for doctors should be mandatory, with an even greater percentage (83%) supporting mandatory disclosure for researchers. However, almost one-third (31%) of those surveyed stated that they were unclear about how the PPSA disclosure requirements operated. Finally, despite concerns that the new regulations might negatively impact physician-industry relations, 72% of respondents felt that the new regulations would not affect their relationship with the life sciences industry.

Figure 4: Effectiveness of information sources

Industry: What forms of marketing do you consider the most effective? (respondents selected all that applied)

Physicians: Which of the following do you find most effective in terms of learning about and prescribing/ordering new medications and novel treatments? (Respondents selected top three)

Free Samples 41% 42%

Detailing 23% 52%

Food/Entertainment 19% 12%

Consulting and speaking fees 28% 5%

CME 17% 57%

DTC advertising 53%

Medical journal advertising 21%

Other 20%

Research grants 3%

Figure 5: What percentage of your annual income stems from your relationship with the industry?

0%

Less than 1%

Between 1% and 10%

23%

70%

7%


Life sciences industry views Investment in health care provider-related complianceThe survey results support the contention that the life sciences industry is undergoing a compliance-related investment cycle, as new legislation (including PPSA) and increased enforcement worldwide necessitate investments in human capital, software upgrades, and process integration to meet reporting requirements. More than three-quarters of the respondents said that their 2011 investment to comply with HCP disclosure requirements was the same or greater than in 2010 (Figure 6); almost the same percentage said that their investment over the next two years (2012-2013) would equal or surpass 2011 expenditures (Figure 7).

On a more granular level, greater than three-quarters of the respondents said they see training programs and software integration and upgrades as consuming the greatest proportion of this increased compliance investment, while 25% also noted that increased staffing would be needed to comply with the PPSA (Figure 8).

Figure 6: What was your investment in HCP transparency-related compliance in 2011?

Bigger than the year before

Same as the year before

Smaller than the year before

39%

57%

4%

Figure 7: What do you anticipate your investment over the next two years in HCP transparency-related compliance to be?

Bigger than in 2011

Same as in 2011

Smaller than in 2011

41%

55%

4%


Industry preparedness and main challengesAlthough PPSA compliance is complex and challenging for life sciences companies, a third of survey respondents said they are 50% done with preparations and hoped to be ready in time while a another third felt that they were 100% ready (Figure 9), despite the fact that final implementing regulations have not been issued.

Quoted in an article regarding the Sunshine Act’s effect on industry for Compliance Week Glenn Engelmann, former general counsel for Astra Zeneca, describes the challenge facinglifesciencescompanies:“Whileitseemslikeaneasy thing, it’s actually a fairly complex task to pull all the information together in a usable format.”3

Whenaskedtoidentifythechallengesofputtinginplace a strategy to comply with the PPSA and other laws, respondents pointed to training of employees (52%), financial expenditures for compliance (43%), understanding requirements (41%), and engaging all the necessary stakeholders (40%) as the key challenges. Far fewer respondents listed data quality and integrity (16%) or software upgrades and integration as a challenge (16%) (Figure 10). It is not entirely clear why data integrity and appropriate software reside so far down the list, but it could point to the fact that companies may not be as ready to comply with the new requirements as the responses in Figure 8 would indicate.

3 Stuart, Alix. “Sunshine Act Putting Heat on Healthcare Firms,” ComplianceWeek,April10,2012,http://www.complianceweek.com/alix-stuart/author/1246/

Leveraging data Whenaskedaboutusingpubliclyavailabledataregardingother companies for strategic purposes, almost half of the respondents (49%) said they were considering or planning to leverage the data, while only 13% had developed significant plans to do so (Figure 11). It seems that the activities of aggregating and disclosing the data in the first place have taken center stage at this time.

Figure 9: How ready is your company for the implementation of the requirements of the Physician Payment Sunshine Act and other new compliance requirements?

We are 100% ready

We are 50% done and hoping to be ready in time

We are 75% done and should be ready in time

We are 25% done and worried we won’t be ready in time

22% 33%

12%

33%

Figure 8: Which compliance-related areas will see the biggest increases over the next two years?(Respondents were asked to select top three areas)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.900002

In-house training programs 48%

34%

26%

25%

11%

3%

In-house software upgrades and integration

Hiring third-party consultants for training

Hiring new full-time employees in legal, sales, marketing and IT to work on compliance programs

Hiring third-party software vendors

Other


challenged to figure out how to achieve compliance in the most efficient, cost-effective manner.

It is too early to tell whether the PPSA will significantly alter the landscape of provider-industry relationships; almost three quarters of the physician respondents seem to think that will not change. On the other hand, there appears to be significant support within the physician community for disclosure. This is particularly true in the research context, where 83% of those surveyed supported mandatory disclosure. This suggests that physicians are more concerned with research bias then with empowering patients to understand physician-industry financial interactions, a potential disconnect with the legislative goals of the PPSA.

Perhaps the most important consideration for the life sciences industry is that the PPSA provides an opportunity to evaluate spending allocations for health care provider relationships. As the survey revealed, allocation of the money that life sciences companies currently and/or plan to spend is not consistent with how providers say they learn. Therefore, while disclosure may allow companies to reduce negative perceptions around interactions, it may also provide an opportunity to improve overall operational efficiency; thereby reducing costs.

Figure 11: To what extent do you plan to leverage publicly available data regarding other companies to inform your strategy?

My company has plans to use the data but is still investigating/planning how available data will be used

Don’t know

My company has significant plans to use and leverage the available data

My company has no plans to use the available data

13%

49%

13%

25%

Conclusions and considerationsAs the survey results illustrate, physicians, the life sciences industry, and even the government are expected to expend significant time, effort, and resources complying with PPSA. Health care providers and the life sciences industry will be

Figure 10: What are the top challenges of putting in place a strategy to comply with the Physician Payment Sunshine Act and other regulatory requirements?

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.90000253.600002

Training employees about new regulatory requirements and collecting data52%

43%

41%

40%

16%

16%

15%

1%

Financial expenditure required

Understanding and keeping current with the requirements of the global regulatory environment

Engaging all necessary stakeholders within the company in compliance programs

Data quality and integrity

Software upgrades and integration

Choosing third-party vendors for compliance solutions

Other


Physician results

What is your medical specialty?

Family medicine/General practice

Other (specify)

Pediatrics

Other internal medicine

OB/GYN

Anesthesiology

Psychiatry

Other*

*Other represents < 2% each of the following specialties: Allergy/immunology, cardiology, dermatology, orthopedics, general surgery, gastrology/gastroenterology, and rheumatology

28%

10%

5%

5%

5%

23%

10%

14%

What is your practice type?

Single private practice

Multi-doctor private practice

Hospital

Outpatient care center

Other

18%

6%

11%

40%25%

Where are you located?

U.S. Northeast

U.S. South

U.S. Midwest

U.S. West

34%

18%

25%

23%

What year were you born?

Before 1945

1945 to 1960

1961 – 1970

1971 – 1980

After 1981

9%

23%

43%

22%

3%

Appendix


Which of the following describes your current relationship with the pharma industry?(Respondents selected all that applied)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.90000253.60000260.300003

I accept free samples


I attend industry-sponsored continuing medical education seminars

I accept food, entertainment and travel

I accept consulting and speaking fees

Other

I accept research grants

65%

58%

52%

35%

16%

12%

8%

Which of the following do you find most effective in terms of learning about and prescribing/ordering new medications and novel treatments?(Respondents selected up to three)

Industry-sponsored continuing medical education seminars


Free samples

Other

Food, entertainment and travel


Research grants

57%

52%

42%

20%

12%

5%

3%


What is your primary source for information about new drugs and novel treatments?

Industry

Colleagues

Medical journals

Internet (including social media) content

Other

17%

13%

5%

14%

51%

Do you derive any financial benefit (speaking and consulting fees, gifts and travel, meals and entertainment) from your relationship with the industry?

Yes 23 %

No 77 %

23%

77%

Over the past year, how has your financial benefit derived from the industry for the following catagories changed?

Decreased substantially

Decreased somewhat

Stayed the same

Increased somewhat

Increased substantially

25%

32% 66% 2

7% 63% 5%

23% 20% 52% 5%

27% 7% 66%

45% 19% 36%

29% 34% 134% 2

Free samples

Food, entertainment, and travel


Continuing medical education (CME) seminars

Research grants

Other


What are your expectations about your financial benefits from the industry for the following catagories during the next year?

Decrease substantially

Decrease somewhat

Stay the same

Increase somewhat

Increase substantially

23%

24% 8% 68%

15% 59% 4%

23% 16% 56% 4% 1

23% 16% 60% 1

26% 23% 48% 2 1

21% 24% 49% 6%Free samples

Food, entertainment, and travel


CME seminars

Research grants

Other

What percentage of your annual income stems from your relationship with the industry?

0.00 %

Less than 1%

1% to more than 50%

70%

23%

7%

How will the tranparency-related compliance laws (such as the Physician Payment Sunshine Act (PPSA) in the U.S.) and other transparency-related regulatory requirements affect

It will not affect it at all

I will limit my financial benefits, such as consulting fees or travel

I will not accept any financial benefits except free samples

I will not accept any financial benefits including free samples

Other

1%

72%

13%

9%

5%


Do you have a clear understanding of the PPSA and other transparency-related regulatory requirements coming in force in 2012?

Yes, very clear

Somewhat clear

Not clear at all

24%

45%

31%

Are you in favor of a public, searchable database of all physician-industry relationships to be accessible by the public?

Yes, as long as patients understand how to interpret the data

No, such a database is an invasion of doctors' privacy

Yes, the more information patients can get, the better

Other

14%

27%

54%

5%

Are the definition of conflict of interest in physician-industry relationships and current regulatory requirements clear to you?

Yes, very clear

Somewhat clear

Not clear at all

43%

42%

15%

Should free samples be exempt from reporting?

Yes

No

72%

28%


In your opinion, has the pre-2012 regulatory environment of the physician-industry relationship led to any breach of ethics?

Yes

No

48%

52%

For which categories of medical players do you believe disclosure should be mandatory?(Respondents selected all that applied)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.90000253.60000260.300003

Researchers

Teaching hospitals

Doctors

Medical associations

Nurses

None

83%

66%

64%

61%

44%

11%

Do you trust information you get from the industry?

Most of the time

Seldom

No

30%

66%

4%


Industry results

Which of the following best describes your company's primary industry sector?

Proprietary pharmaceuticals

Generic pharmaceuticals

Medical devices and/or diagnostics

Biotechnology

Consumer health

Animal health

Other

2%

6%

17%

7%

19%

30%

19%

What are your main functional roles?(Respondents selected up to three)

0.0000006.70000013.40000120.10000126.80000133.50000140.200002

General management

Strategy and business development

Finance

Compliance

Operations and production

Risk

Other

Legal

41%

39%

26%

18%

17%

15%

8%

6%

What is your job title?

Board member

CEO/president/managing director

CFO/treasurer/controller

COO

CIO/technology director

CMO/head of marketing

Chief Compliance Officer

Chief Risk Officer

SVP/VP/director

Head of business unit/head of department

28%

9%

5%

4%

3%1%

14%28%

3%

5%


What was your company's revenue during the most recent fiscal year?

$500 million to $999 million

$1 billion to $4.9 billion



$20 billion plus

12%28%

24%

23%

13%

Where are you located?

North America

Europe and United Kingdom

Asia/Pacific Rim

Central or South America

Middle East

36%

47%

2%

10%

5%

Please specify your country of residence in the North, Central or South America region.

United States

Brazil

Other

91%

2%7%


Please approximate the percentage of your marketing budget currently attributed to the following catagories.

Under 10%

11% to 25%

26% to 50%

51% to 75%

Over 75%

Don't know

35%

21% 9% 4% 8% 4% 54%

41% 21% 9% 6% 6% 17%

31% 20% 15% 9% 10% 15%

24% 13% 6% 6% 15%

41% 20% 10% 9% 3% 17%

43% 26% 9% 7% 2 13%

39% 18% 14% 4% 2 23%

51% 17% 6% 2 3% 21%

Continuing medical education (CME) and research for HCPs

Direct to consumer (DTC) advertising

Medical journal advertising

Other

Free Samples

Detailing

Food, entertainment and travel for health care professionals (HCPs)

Consulting and speaking fees for HCPs

Please specify your country of residence in the Europe, Middle East, and Africa region.

United Kingdom

France

Belgium

Other*

*Represents countries < 2% each. Countries include Germany, Ireland, Italy, Nigeria, and South Africa.

71%

10%

17%

2%

Please specify your country of residence in the Asia Pacific region.

India

China

71%

29%


Which segments of your marketing budget have increased or decreased over the past year?

Significant increase (>15%)

Moderate increase (5% to 15%)

Slight increase (<5%)

No change

Slight decrease (<5%)

Moderate decrease (5% to 15%)

Significant decrease (>15%)

6%

4% 6% 12% 59% 9% 4%6%

8% 10% 13% 51% 7% 3%8%

8% 11% 57% 7% 29%

4% 8% 15% 49% 13% 7% 4%

6% 9% 14% 49% 10% 7%5%

6% 10% 10% 57% 9% 4%4%

7% 9% 11% 56% 8% 4% 5%

CME and research for HCPs

DTC advertising


Free Samples

Detailing



What segments of your marketing budget do you expect to increase or decrease over the next year?

Significant increase (>15%)

Moderate increase (5% to 15%)

Slight increase (<5%)

No change

Slight decrease (<5%)

Moderate decrease (5% to 15%)

Significant decrease (>15%)

5%

5% 9% 12% 57% 9% 4%4%

7% 9% 17% 48% 11% 4%4%

8% 13% 55% 11% 4%4%

3% 6% 17% 56% 9% 5% 4%

5% 7% 16% 53% 10% 3%6%

5% 8% 12% 59% 10% 24%

6% 7% 13% 59% 7% 5% 3%


DTC advertising


Free Samples

Detailing




Which do you consider the most effective forms of marketing?(respondents selected all that applied)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.90000253.600002

Direct to consumer advertising

Free samples


Detailing


Food, entertainment and travel for HCPs


53%

41%

28%

23%

21%

19%

17%

Which of the following statements best reflects your position on the disclosure of HCP/Health Care Organization payment information?

Disclose all Heath Care Professional/Health Care Organization payment information that will be mandated for disclosure by the Physician Payment Sunshine Act and other related regulatory compliance (such as free samples)

Disclose most of the HCP/HCO payment information required by the PPSA

Disclose some HCP/HCO payments

Do not disclose any HCP/HCO payments

12%

6%

22%

60%

How ready is your company for the implementation of the requirements of the Physician Payment Sunshine Act (PPSA) and other new compliance requirements (such as free samples)?

We are 100% ready

We are 50% done and hoping to be ready in time

We are 75% done and should be ready in time

We are 25% done and worried we won't be ready in time

12%

22%

33%

33%


What are the top challenges of putting in place a strategy (encompassing people, process and communications) to comply with the PPSA and other regulatory requirements?(Respondents selected up to three)

Training employees about new regulatory requirements and collecting data

Financial expenditure required

Understanding and keeping current with the requirements of the global regulatory environment

Engaging all necessary stakeholders within the company in compliance programs

Software upgrades and integration

Data quality and integrity

Choosing third-party vendors for compliance solutions

Other

52%

43%

41%

40%

16%

16%

15%

1%

What do you anticipate your investment over the next 2 years in HCP transparency-related compliance will be?

Substantially bigger than in 2011

Somewhat bigger than in 2011

Same as in 2011

Somewhat smaller than in 2011

Substantially smaller than in 2011

13%

42%

1%3%

41%

What was your investment in HCP transparency-related compliance in 2011?

Substantially bigger than last year

Somewhat bigger than last year

Same as last year

Somewhat smaller than last year

Substantially smaller than last year

15%

42%

2%2%

39%


Which compliance-related areas will see the biggest budget increases over the next two years? (Respondents selected up to three)

0.0000006.70000013.40000120.10000126.80000133.50000140.20000246.900002

In-house training programs

In-house software upgrades and integration

Hiring third-party consultants for training

Hiring new full-time employees in legal, sales, marketing and IT to work on compliance programs

Hiring third-party software vendors

Other

48%

34%

26%

25%

11%

3%

Who owns PPSA and related compliance within your organization?

General management

Legal and compliance

Sales and marketing

Other

27%

4%8%

61%


How will the reporting requirements of the PPSA and related compliance affect your business? (Respondents selected all that applied)

0.0000006.70000013.40000120.10000126.80000133.50000140.200002

It will not have a significant effect on our business

It will lead to a decrease in promotional spending to doctors and teaching hospitals, thus hurting our marketing efforts

It will lead to a decrease in promotional spending to doctors and teaching hospitals, resulting in savings

It will hurt our relationships with HCPs and teaching hospitals

It will help our business, as more transparency will improve our image

It will help our business, as the new understanding of aggregate spending will help better allocate resources

Other

39%

26%

23%

17%

15%

14%

2%

In addition to PPSA in the United States, there are comparable acts in Japan and in the United Kingdom. How would you say that your company is approaching the challenges posed by these regulations?

My company is developing an integrated approach and plan to address regulations around the world

My company is addressing the regulations separately, by country and regulation

Don't know

37%

22%

41%

To what extent do you to plan to leverage the publicly available data regarding other companies to inform your strategy?

My company has plans to use the data but is still investigating/planning how available data will be used

Don’t know

My company has significant plans to use and leverage the available data

My company has no plans to use the available data

13%

49%

13%

25%


Demo 23 How is your company planning to use the publicly available data? (Respondents selected all that applied)

0.0000006.70000013.40000120.10000126.80000133.500001

Data mining to identify emerging trends—spending

Data mining to identify emerging trends—high-volume activities

Data mining to identify emerging trends—top physicians

Data mining to identify emerging trends—high-dollar activities

Proactively identifying non-compliance issues

Data mining to identify physicians used by competitors for similar activities

Fair market value analysis

35%

35%

31%

28%

26%

22%

18%



Authors

Contacts

David HodgsonDTTL LSHC Enterprise Risk Services Leader+1 973 602 [email protected]

Seth WhitelawDirectorDeloitte & Touche LLP (United States)+1 215 789 [email protected]

Special thanks to Brenna Sniderman (Forbes Insights), Kasia Moreno (Forbes Insights), Patsy Bolduc (DTTL) and Terry Koch (DTTL) for their contributions to this report.

For marketing and PR inquiries, please contact:Terry [email protected]+1 313 394 5548

About Life Sciences and Health Care at Deloitte Touche Tohmatsu Limited (DTTL)DTTL’s life sciences and health care (LSHC) industry group is composed of more than 6,400 professionals in more than 65 countries. These professionals understand the complexity of today’s life sciences and health care industry challenges, and provide clients with integrated, comprehensive services that meet their respective needs. In today’s environment, LSHC professionals from across the Deloitte network help companies to evolve in a changing marketplace, pursue new and innovative solutions, and sustain long-term profitability.

For more information about the DTTL LSHC industry group, email [email protected] or access www.deloitte.com/lifesciences.

Additional DTT Life Sciences and Health Care Industry Group contacts:

DTTL Life Sciences and Health Care (LSHC) Industry LeaderReynoldW.(Pete)Mooney+1 617 437 [email protected]

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