Pharmaceutical manufacturers that are looking to implement a new ERP system will invariably ask about options for meeting requirements of the Sunshine Act, which was enacted to protect consumers by ensuring transparency in the reporting of financial relationships between pharmaceutical companies and health care providers (HCPs). While pharmaceutical companies generally purchase a software system specifically designed to track their aggregate spending to HCPs, the ERP system generates much of the information that is fed into the aggregate spend system.
Typically, money flows from pharmaceutical manufacturers to health care providers in 3 forms, that are generally handled in 3 very distinct manners:
- AP invoices directly to HCPs: Vendors that are HCPs are defined as such in the ERP system. Any expenses that are booked in the ERP system directly to HCP vendors are pushed to the aggregate spend system via an integration. Typically, a relatively small number of HCPs become direct vendors in the ERP system. The process of setting up new vendors is generally a highly controlled process that lends itself to accurately defining and identifying an HCP
- Employee expense reimbursement: Employees of the pharmaceutical company meet with HCPs and incur expenses that need to be reimbursed to them by the company. Assuming the company has an expense reimbursement system (such as Concur, for example), the expense reimbursement software generally just feeds the core accounting (general ledger) data to the ERP system, and sends the HCP spend information directly to the aggregate spend software. It is therefore necessary to have the HCPs defined in the expense reimbursement system, but the ERP system is not involved in this process.
- AP invoices to 3rd party vendors that benefit HCPs: While it is possible to capture this data in the ERP system (on a custom field linked to the PO or invoice) and push it to the aggregate spend system, there are some complicating factors that lead many companies to opt to manually enter these transactions into the aggregate spend software or else upload vendor documents directly to the aggregate spend software in addition to recording the invoices in ERP:
- Timing: At the time that a PO or invoice is entered, do we necessarily know which HCPs will benefit from the spend? For example, speaker bureau invoices often arrive in advance of the list of attendees (HCPs)
- Accuracy: HCPs that benefit from expenses incurred with 3rd parties are can be very large in quantity. Ensuring that the correct HCP is selected and linked to an expense can be difficult, especially when many health care providers may have similar names (or even the same names). In such cases, AP clerks that have no direct knowledge of the circumstances surrounding the expense could have a difficult time selecting the correct HCP. Aggregate spend software systems typically have matching algorithms to accurately identify HCPs.
This article was written by Matthew Boese, Partner at Tridea Partners, a Gold Certified Microsoft Dynamics Partner.