Guest blog written by Patrick Taylor, CEO of Oversight Systems.
As of August 1, medical device manufacturers are required by law to report all single transactions above $10 or any series of related transactions totaling more than $100 in a year. The Physician Payments “Sunshine Act” (part of the Patient Protection and Affordable Care Act) has, as you can imagine, thrown medical device manufacturer’s into a frenzy. Prior to the new legislation, transactions were typically recorded in a manual, ad hoc manner. Now, compliance depends on the accuracy in reporting what could possibly be millions of data points dispersed across expense reports in the T&E system and invoices in Accounts Payable.
Companies have until March 31, 2014 to submit their reports, which means they need a solution yesterday. Transaction monitoring, widely used to detect fraudulent behavior within organizations, could provide medical device manufacturers with the support they need to comply with the new rules. Providing a digital record of all business transactions, transaction monitoring would not only allow companies to confidentially report on all transactions as required by the Centers for Medicare & Medicaid Services, but would also help companies identify duplicate charge submissions, outstanding credits, misclassifications, policy misuse, black listed/watch list vendors, patterns of high-risk behavior and more.
While the Sunshine Act may be giving organizations pains today, it could save them from undue legal litigation in the future. Think back to the Morgan Stanley story: one of the managing directors committed fraud, yet the company was exonerated based on their compliance initiatives. Specifically, Morgan Stanley had up-to-date policies, ongoing and effective training, and transaction monitoring!
Integrating transaction monitoring into your compliance program will allow you to comply with Sunshine Act transparency rules, while simultaneously bolstering your compliance program overall. Transaction monitoring was tailor-made to integrate with policy management, training and other compliance systems. Adding transaction monitoring to your program means you’ll have continuous transaction analytics at your fingertips — you have your polices in place, you conduct your training — and with transaction monitoring, you have an added layer of protection so you can attest to the success of your other compliance initiatives.