Companies will soon be publishing their annual disclosures of transfer of values (TOV) to healthcare professionals (HCPs) and healthcare organisations (HCOs). In the UK, HCPs are invited by letter to view their TOVs via the central database during the month prior to publication, however this only shows the total value by company, any corrective works after that point require considerable re-work and re-submission. The aim of course is to have the data validated and absolute confidence in its completeness before submission and that’s where pre-disclosure at a company level plays a crucial role.
So what is pre-disclosure?
In advance of publishing or submitting their disclosure reports to central industry repositories (such as the https://search.disclosureuk.org.uk in the UK), many companies send out a statement detailing the TOVs which are to be reported against an HCP. Allowing the HCP to preview the detail and familiarise themselves with how the total values are comprised.
Why do companies do it and what are the benefits?
Pre-disclosure is considered as one of the industry best practices for several reasons:
Significantly reduces the number of queries - Many of the HCP queries post submission / publication are to seek clarification of the values disclosed against them. This is particularly helpful for indirect TOVs where HCPs may not be fully familiar with the value for items such as registration fees etc that the company has paid for on their behalf.
Prevents breaches of the code and incorrect data being disclosed against the wrong individual – Any potential errors or incorrect allocations of ToV to individuals can be spotted and corrected prior to public disclosure. Thus, preventing some of the recent high-profile cases of payments being publicly disclosed against the wrong HCP.
Ensures the HCPs principle place of practice (PPoP) is correct - Another major cause of re-submission. Good pre-disclosure practices will also declare the PPoP and allow the HCP to advise if it requires updating.
Enhances the relationship with HCPs - showing care and consideration for them and their data.
Re-emphasise the basis of disclosure – This is particularly important for companies operating on a legitimate interest basis, to express the basis for disclosure and company’s commitments to transparency. For those companies that allow free choice, pre-disclosure offers an opportunity to validate the consent choices especially when there may be a conflicting choice or where consent hasn’t been captured.
Greater chance of review – You can track and identify who has and who hasn’t confirmed their ToVs and take follow up action
How do companies do it?
The optimal time to complete the pre-disclosure process is as early as possible, with the majority of activity taking place during February and March. Some companies issue to those HCPs that have consented, others issue to all and provide clarity on whether the data will be publicly disclosed or not. The typical approach is to send the data to individuals via email, however there are risks of personal data being available on email and the potential for breaches that need to be considered and best managed.
To find out more about how PAYCE can help you with your pre-disclosure practices, visit www.payceportal.com/pre-disclosure