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Former Member
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I have had several questions coming from the SAP sales team and customers about the 'Sunshine Act' and how SAP's plans to help in compliance or even create competitive advantage upon realization of this new set of data.  The Physician Payment Sunshine Act is a part of the US Federal ‘ACA’ or Affordable Care Act.  In short, it requires all Medical Device, Drug and Medical Supply companies to report how much they spend with individual healthcare practitioners.  Aggregating Healthcare Practitioner (HCP) Spend is growing rapidly in terms of complexity and jurisdiction as similar requirements are enacted globally and locally.  Accurate accounting for spend and compliance for each HCP and/or organization is required in order to comply with regulations and mitigate risk associated with these investments. 

I have had the good fortune to spend several days with a group of customers, SAP experts and a tax consulting firm to understand what compliance looks like and define how to leverage existing systems and SAP technology to address these requirements.  Once compliance and a complete view of these investments is achieved, is it possible this data could also be used to create competitive advantage?   This raises some questions:

How does HCP Spend reporting impact your business?

  1. Pharmaceutical and Medical Device Manufacturers will be required to report payments, gifts,  and honoraria which had not been required in the past
  2. Historically these transactions are captured in multiple systems of record and without appropriate detail to ensure compliance
  3. Existing investments in technology, training and process require current systems to be left in place and utilized as replacement would be overly burdensome
  4. Third party distributors and sales agents involved in the sales process must also be contemplated to be compliant, systems to ‘tie-in’ the appropriate level of financial information must be created preferably in an automated fashion.

How can Life Science Companies harness this data?

  1. Priority one is ensuring compliance, this requires a robust reporting mechanism to minimize costs across reporting countries and states
  2. Once complete these reports and data may yield new and more comprehensive insight into where investment dollars and resources are going 
  3. Correlating physician response to new campaigns, products and events and understand behavior and ROI should be achievable
  4. Provide your sales and marketing organizations a means to educate, interact with and enable HCPs confidently and with greater effect
  5. Brand enhancement and protection based on spend and investment priority

As we develop the final architecture and deliverables I will follow-up on this to help further SAP’s ability to positively impact our customers’ business and provide new solutions and opportunities to Run Better.

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