-
Novo Nordisk Sunshine Report Accepted by CMS
The Centers for Medicaid and Medicare Services (CMS) accepted
Novo Nordisks first Sunshine disclosure report of payments and
transfers of value to Health Care Providers and Institutions (HCPs
and HCIs) on July 1, 2014. As awareness around Sunshine grows, Novo
Nordisk employees, especially those interacting with HCPs and HCIs,
may be approached with requests for information. Please remember
the following items in regards to the Sunshine disclosure report,
the Sunshine act, or the CMS dispute process:
1. Do not respond to HCP or HCI questions individually. Direct
all questions to the Compliance Department at
[email protected].
2. Respond immediately if contacted by the Compliance Department
with inquiries regarding expense disputes to ensure Novo Nordisk
meets its obligations.
3. Consult the Sunshine GlobeShare page for information,
resources, and Frequently Asked Questions (FAQs) to help guide you
through Sunshine.
4. Direct questions of your own to the Compliance Department at
[email protected]. Questions, once answered,
will become part of the Sunshine FAQs.
Additionally, the Compliance Department sent a letter to all
vendors reminding them to review their obligations around Sunshine
data reporting and invoicing. All vendor contract owners and vendor
relationship managers should also examine the contract terms to
enable assistance when required.
-
Key Dates
Sunshine Update
Important Points
Pre-submission reports were shared with a subset of NNI KOLs /
physicians in February, which may increase questions from
customers
If a physician contacts you directly about Sunshine
dispute-related expenses, please direct him/her to
[email protected]. Do not respond
individually.
Respond immediately if contacted by the Compliance Dept. with a
dispute expense inquiry
Timely review communications and GlobeShare resources
Continue accurate reporting in Concur and InterFace
1
June 18 Novo Nordisk submitted report to CMS Covers activity
from 31-Aug31-Dec 2013
Sunshine Filing Dispute & Corrections Public Posting
August & September* Physicians review of data on government
site Do not respond if physicians ask expense questions *awaiting
confirmation from CMS
By September 30th CMS will make data available on a public
website
In-Office Meal Reminders
Call ahead to obtain expected headcount and non- meal/snack
participants
Accurately enter HCPs and count of Staff
Stay within the NNI policy limit of $25 per person for in-office
meals
Ensure Concur entries reconcile with in-office attendance
sheet
Interface Program Reminders
All attendee must sign into the program
Close out interface programs within 2 days
Ensure reported attendees reconcile with attendance sheet
2
4
5
3
-
Systems & Services > General Legal > US Healthcare
Reform & Novo Nordisk > Open Payments Sunshine Act
FAQs
Attendance Sheets/ Concur Health Care Professionals
Reportable Marketing Materials
NNI Attendance Sheets
Completing In-Office Attendance Sheets & Submitting HCP
Information into
Concur FAQs
Concur In-Office Program FAQs
NNI In-Office Meal Allocation (leave behind)
Sunshine Letter for Healthcare Professionals And
Institutions
Sunshine Q&A Guideline
NNI Policies: Found on Sunshine Toolkit page under key
documents
Reportable Marketing Materials Distribution Guidelines
Sunshine & State Reporting reportable marketing materials
decision tree
Understanding What
Materials and Persons are Reportable
Please remember that there is an array of resources available on
the Sunshine Globeshare Page to help guide you through Sunshine
related questions and to assist you with Sunshine Act
compliance:
Sunshine Act Tools and Resources:
Questions [email protected]
Compliance Helpline: (609) 937-3816
Policies Business Ethics Interactions with U.S. Health Care
Professionals and Health Care Institutions [Policy 140845] Employee
Expense Reimbursement [Policy 140841]
-
Sunshine Review and Dispute Period closes X date The review
dispute and correction period closed on X date. Data is expected to
be published by CMS on or about September 30, 2014. As a reminder,
Physicians have to the end of the year to submit disputes.
Direct all questions to the Compliance Department at
[email protected] or consult the Sunshine
GlobeShare page
Please remember: If a physician approaches you about reported
information, or an inquiry/dispute please forward questions to
[email protected]. A team from Compliance will
investigate all inquiries/disputes and respond to the physician or
teaching hospital. Updates will be provided to applicable NNI
employees.
If you are contacted by the Compliance Department for additional
information or supporting
documentation related to a reported payment please respond in a
timely manner. If you are contacted by a member of the media, refer
the contact to a media relations representative in
the Communications and Public Affairs department via the
Communications Hotline at (609) 514-8400.
-
Sunshine Review and Dispute Period closes X date
The$review$dispute$and$correc2on$period$closed$on$X$date.$$$Data$is$expected$to$be$published$by$CMS$on$or$about$September$30,$2014.$As$a$reminder,$Physicians$have$to$the$end$of$the$year$to$submit$disputes.$$
Direct all questions to the Compliance Department at
[email protected] or Consult the Sunshine
GlobeShare page
Please remember: If a physician approaches you about reported
information, or an inquiry/dispute please forward questions to
[email protected]. A team from Compliance will
investigate all inquiries/disputes and respond to the physician or
teaching hospital. Updates will be provided to applicable NNI
employees.
If you are contacted by the Compliance Department for
additional
information or supporting documentation related to a reported
payment please respond in a timely manner.
If you are contacted by a member of the media, refer the
contact
to a media relations representative in the Communications and
Public Affairs department via the Communications Hotline at (609)
514-8400.
-
Sunshine Communication Timeline July 14: Vendor Letter
From NNI Sunshine July 17: High Level sunshine Update
All employee (NovoLink, plasma screen) Tip of the week (sales
POA handout)
o Check w/ BioPharm/ CMR/ DE/ Trade July 22: Dispute Process
Leadership mess (CMR LT/ BLT/ DE/ Trade/ Sales) Jeff to
determine list Talking points to be included
July 23: Dispute Process
Managers (more specific leadership) July 24: Dispute Process
NovoLink (general) Sales (specific) Plasma screens Ad space
Beginning August: High Level Sunshine update
All sales organization Updated FAQ
Mid- August: Dispute Process
Plasma screen (reminder) AD space (reminder)
Mid- September: Data goes public (w/ talking points)
NovoLink Plasma screens Sales commnuications (specific)
End September: ET Sunshine Update October: ET Sunshine
Update
-
Weekly Field Communications Biopham: Monday/Tuesday CMR: every
other Thursday (1 edition) Diabetes Sales: every Thursday
(management, all field) DE: ??? Trade: ???
TBD List
Sunshine HCP brouchure Action
ABYR: watermark IAAW: plasma screen DAVE: High level update
IAAW/ ABYR: import to InfoPath