Open Payments Data Analysis & Compliance Effectiveness Go Hand-in-Hand

Dr. Seth B. Whitelaw, Editor for the Policy & Medicine Compliance Update  (1)

As Summer 2020 begins winding down, we are now in our sixth full-year cycle of Open Payments data and our second major update to the Justice Department’s guidance on evaluating corporate compliance programs.  Putting the two together means that life science companies have an express mandate from the DOJ to use available data to monitor compliance program effectiveness, and a rich set of data to use for the monitoring.

Cresen Solutions has developed a tool to analyze Open Payments data, PowerCMS™.  PowerCMS™, launched in July 2019, as a web-based application.  It is both free and free-standing, and the basic application costs nothing to access. Nor is it t part of another transparency system or reporting tool.  Now for 2020, Cresen has improved the capabilities of the free tool and launched a more robust subscription version too.

We now have many years of Open Payments reporting under our belt and have been writing about the Physician Payment Sunshine Act and CMS Open Payments for a long time.  Neither publication endorses a single compliance approach or technology solution, but once again, we would be remiss if we did not cover the updates to Cresen Solutions’ web-based application. As we noted when it launched in 2019, PowerCMS™ is both.  Since its debut, Cresen has expanded the tool’s capabilities and launched a subscription version, which allows the entire data set to be downloaded and compare the detailed spending patterns on multiple physicians simultaneously.

The PowerCMS™ tool in either version allows a company to easily create custom analyses of Open Payments data from 2015 to 2019.  For example, you can easily see spending trends with physicians (and teaching hospitals) by product and category of spend (Figure 1).

Figure 1:  Spend analysis by year for Product X

PowerCMS™ also lets the user drill down further to examine the trends in spending for the past five years for a specific product across the top 20 physicians, otherwise known as Key Opinion Leaders (“KOLs”).  As Figure 2 illustrates, 94.3% of payments made to the top KOLs for this product were for speakers’ programs, while 5.7% went to research.  At a minimum visualizing the information allows compliance to take a truly risk-based approach and prioritize where to deploy its limited resources.

Figure 2:  KOL Analysis For Product X Over Time

Users can also create detailed spending profiles for specific physicians.  Users also can see if a physician, or the company, itself, is an outlier when compared to others in the industry.  However, while the tool quickly provides outlier data, it does not replace the need for further human analysis.

Perhaps the most significant change to PowerCMS™ is the ability to see which KOLs the company and its competitors interact with together with the relevant spending patterns in one place (Figure 3, bottom right).

Figure 3:  Competitive KOL Analysis For Products X & Y

According to Rob Zelinsky, Vice President of Customer Engagement, the competitive KOL analysis “simply enhances the value of PowerCMS™ to our users, giving them yet another off-the-shelf view of the data.”

Cresen sees this as an opportunity for compliance to provide real value to their business partners.  As Cresen Solutions’ Managing Partner, Emil Saladik put it, “this is an opportunity for us to use our expertise and pay it forward.  We believe that every life science company, no matter the size, should be using the CMS data to improve both their compliance functions and their business.  In 2020, the stakes of not doing couldn’t be higher,” referring to the recently updated DOJ guidance.

Having seen PowerCMS™, we conclude that despite the known limitations of the CMS data,  the tool continues to provide a powerful resource  for compliance departments of all sizes.  Now with the launch of the subscription version, it offers even greater capability for those wanting to do more.  For those interested in using or learning more, Cresen’s PowerCMS™ can be accessed by anyone who follows this link and fills out the registration form using a valid organization or company email address.

[1] The Policy & Medicine daily and the Policy & Medicine Compliance Update do not endorse a single compliance approach or technology solution.  This article is provided as a review and not an endorsement.