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med meetings compliance

Open and Shut, for Now

Extremely high compliance rates for the Open Payments law means that medical-event planners and their colleagues are doing things properly. But the work is not done.

This past month, the degree of transparency in the medical events field received a stamp of approval, when the United States Department of Health and Human Services Office of Inspector General (HHS OIG) completed a review of the Open Payments data for accuracy, precision, and consistency in reporting.
 
OIG was prompted to perform this review because the transparency of the Open Payments program not only reveals the nature and extent of relationships between physicians and teaching hospitals with applicable manufacturers and group purchasing organizations, but that transparency also has the potential to discourage the development of inappropriate financial relationships.
 
Naturally, the public can only benefit from the information if it is complete and accurate. With that said, the records that were reviewed contained the required fields 99.9 percent of the time. This means that far less than 1 percent of examined records had missing data elements—11,463 out of 11.9 million total records. Further, the vast majority of the information missing was in fields such as physician specialty (75 percent) or name of the third party that received the payment (21 percent).
 
Such a degree of accuracy and completeness helps flush out professional missteps, accidental or otherwise. For instance, a recent ProPublica article published in the New York Times exposed the medical director for Memorial Sloan Kettering Medical Center in New York City for not disclosing his interests in major journal articles—interests which were easily found in the Open Payments system.    
 
As the HHS OIG report shows, medical meeting planners are surely doing things right in collecting the data that is applicable to Open Payments reporting. However, planners should remain diligent in collecting conflict-of-interest forms, and corporate planners should also stay diligent in collecting any necessary meal information. As an education provider, we provide a link to Open Payments Data and encourage our faculty to review their data prior to submitting their conflict-of-interest forms. This is just one example of how meeting planners can help faculty ensure that they are accurately reporting their potential conflicts of interest.  
 
Now, this is not to excuse a clinician who fails to disclose relevant information, but do keep in mind that not all interests are necessarily related to the activity or article. Then again, in the push to be sufficiently transparent, our faculty need to understand the value of disclosure in that it allows the audience to make informed decisions based on the presentation and background of the presenter.
 
There is no absolute straight line for disclosure; faculty may consider that work for one company has no bearing on research, publications, or presentations supported by another. In the end, though, meeting planners need to stay focused on collecting interest data and reporting on payments such as meals to certain attendees.
 
Thomas Sullivan is founder and president of Rockpointe Corp., a medical education company located in Columbia, Md. Sullivan's firm produces the online publication Policy & Medicine
 
 

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