Currents

The Good, the Bad, and the Ugly

Plan, Test, and Standardize to Drive Predictable Transparency Reporting

Do you seem to keep running into the same problems every year during transparency reporting?

You start with The Good. You think your data is complete, clean, and there won’t be a lot of work to do. You are ready for a quick and easy reporting cycle. This year should be easier than last year.

Then The Bad arrives, “We ran the reports and identified a few items that need remediation before submission. Please review and return as soon as possible so we can meet reporting deadlines.”

Finally, there is The Ugly. You open the attachment expecting a handful of records. Instead, you find ten tabs containing hundreds, or even thousands, of errors. There are missing NPIs, records without Recipient Types, invalid state licenses, duplicate records, missing travel city and state, the list can go on and on.

Suddenly what seemed like a straightforward reporting cycle becomes a last-minute scramble. The reality is that transparency reporting doesn’t have to be so hectic, but it does take consistent and proactive effort.

The good news? There are steps you can take to prevent that fire alarm.

Here is The Good, The Bad, The Ugly of it:

The Good: Planning Ahead

Organizations with the smoothest reporting cycles begin preparing well before reporting season

Establish a consistent and easy-to-maintain quarterly closeout process. This will help your stakeholders and vendors understand the importance of transparency reporting at your organization. It will also help you develop a consistent habit of reviewing your overall transparency program and your data.

What does a quarterly closeout look like?

• Reach out to stakeholders and vendors to collect the data quarterly
• Collect all the data from all your sources
• Review any missing data or transactional outliers with your stakeholder or vendors once per quarter
• Discuss changes to your overall transparency program (e.g., Clinical is engaging with a new CRO)

Communication and small corrections made throughout the year are far easier than large-scale cleanup projects when reporting season approaches.

The Bad: Being Blinded by the Truth

Error reports, dashboards, and file logs are helpful tools, but don’t always give you the full picture of your data.

When you are only looking at specific issues, you can sometimes lose sight of the bigger picture. Run test federal and state reports and corresponding Validation Reports to get a holistic view of your data.

Seeing the full picture and format often reveals issues that isolated error reports miss.

The Ugly: Getting the Details Right

The data is just one part of an overall successful transparency reporting season. Your stakeholders’ understanding and buy-in, the systems, and your overall process are all essential parts of your transparency program.

Know Your HCPs and HCOs

Review your list of HCPs and HCOs on a quarterly basis and identify any new vendors that might be applicable for reporting. Work with your procurement or contracting teams to flag vendors during onboarding to ensure they are properly classified for transparency reporting purposes.

Make Data Collection Easier

One of the biggest contributors to poor data quality is overly cumbersome or complicated data collection processes. Standardization is one of the most effective ways to improve data quality.

Consider utilizing AI, implementing smart templates, or updating systems:

• Provide dropdowns/picklists for common fields (e.g., State, Recipient Type, Natures and Purposes, etc.)
• Automate field validation (e.g., NPI being 10 digits, date format, state abbreviations, etc.)
• Call out required fields

This keeps your data consistent and reduces back-and-forth with your transparency system vendor for errors in your data collection.

Confirm Workflows Before You Need Them

Establish a checklist of activities that need to be completed for each federal and state report, prior to submission:

Before reporting season begins, confirm:

• Are we registered and do we have access to the appropriate portals?
• Are there additional actions we need to take before submission (registrations, code of conduct review, representative licensing, etc.)?
• Who else needs to review or attest to the data before submission? Are they available or will they be on vacation at that time?

The last thing you want is a completed file and no way to submit it.

The Bottom Line

Transparency reporting is hard enough – don’t make it harder on yourself!

Organizations that succeed year after year focus on a few key principles:

• Communicate with stakeholders consistently
• Simplify data collection
• Leverage technology to enable bulk remediation
• Review data in a holistic manner
• Manage vendors proactively
• Validate reporting outputs before deadlines
• Drive the submission process with strong project management

When those practices become part of your program, transparency reporting becomes less of an annual emergency and more of a predictable process. These principles work whether you are reporting a thousand or a hundred thousand transactions. 

When done consistently, The Good starts to outweigh The Bad and The Ugly.

Need Help?

Building and maintaining an effective transparency program requires significant time, coordination, and expertise.

Our Transparency Managed Services (TMS) team helps organizations establish sustainable reporting processes, improve data quality, engage stakeholders, conduct remediation, identify key data errors and outliers, and prepare for federal and state transparency submissions.

If you’re spending valuable time chasing errors and remediation requests, reach out to us. The TMS experts at Potomac can free your team up to focus on strategic priorities while we focus on turning The Bad and The Ugly into The Good.

Graham Rich, Director, Potomac River Partners | grich@potomacriverpartners.com

Graham began supporting Potomac’s transparency clients from 2013 to 2018. He has led Potomac’s Transparency & Aggregate Spend service line since rejoining the firm in 2021, serves as practice area lead for global transparency requirements, and leads the firm’s IT and finance functions.

In his capacity as Potomac’s transparency expert, Graham helps life sciences companies of all maturities, sizes, and therapeutic areas meet requirements throughout the full U.S. Federal Sunshine, state, and global—including EFPIA and other international frameworks—reporting lifecycles, from initial system implementation to steady-state operational support. He also develops and implements transparency systems and conducts gap and data analyses.

Graham advises industry leaders regarding transparency and aggregate spend subject matter and has led presentations at national conferences on topics including CMS Open Payments audit readiness and transparency program stress-testing.