Central Database Working Group
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A Centralised Reporting System for Medicines Australia Member Companies’ Payments and Transfers of Value to Health Care Professionals
On 24 April 2015 the ACCC issued its final determination granting conditional authorisation of Edition 18 of the Medicines Australia Code of Conduct for a period of five years. The authorisation became effective on 16 May 2015.
A condition of the authorisation is that Medicines Australia must use reasonable endeavours to develop and implement a Central Reporting System (CRS) which will allow the public to access information on payments and transfers of value from all companies to healthcare professionals in a single location, via the internet. This condition also requires Medicines Australia to provide regular six-monthly reports identifying the steps taken each reporting period to develop and/or implement a CRS.
Centralised Database Working Group
Medicines Australia and the Centralised Database Working Group (CDWG), comprising personnel from Medicines Australia’s member companies, have taken steps to develop and implement a CRS.
Since the third progress report published in May 2017, the Working Group has undertaken the following work.
Preparation of a description of the requirements for a Central Reporting System
Since May 2017, Medicines Australia and the CDWG conducted consultation on the CRS specifications that were developed in conjunction with the external ICT specialist. As described in our May report, this specification included the checking of healthcare professional identity and confirmation of their unique identity. This matching of details would present, when searched by a consumer, a consolidated list of that unique healthcare professional’s data.
As previously identified, Medicines Australia and the CDWG considered options employed overseas in designing the initial specifications for the CRS. The concept of the CRS was initially modelled on the system used by the Association of the British Pharmaceutical Industry (ABPI), in collating data consistent with the European Federation of Pharmaceutical Industries and Associations (EFPIA) requirements.
Following development of the initial CRS specification, wide ranging consultation was undertaken across the entire membership in various forums, as well as discussions with the Medicines Australia Board. This consultation exposed some of the challenges associated with implementing a complex system such as that used by the ABPI. The key challenge was the complexity of developing a system that matched healthcare professionals across multiple companies and various data points. A CRS that could conduct such a comprehensive matching exercise would require both technological and human intervention to connect data points, using various data characteristics to identify potential matches, as well as physically verifying matches in person where there was a possible mismatch. Achieving this would require extensive involvement by external vendors which have the requisite personnel to undertake these healthcare professional data matching activities. The complexity of such a system would result in a lengthy build time and considerable ongoing operating costs while adding limited additional value in terms of the information ultimately available to members of the public.
In the light of these challenges, Medicines Australia and the CDWG considered other options that would deliver a searchable dataset in a more straightforward, cost effective and achievable manner. In doing so, Medicines Australia has removed the burdensome healthcare professional matching requirement and has instead developed specifications for a system that enables robust searching of the data in a similar but more straightforward manner. These specifications detail functional and non-functional requirements in the same way the large-scale CRS did, and the expectations of swift response times and ease of use are maintained. The search functionality would enable a consumer to interrogate the data using several criteria to filter records, and would present a report showing ‘look alike’ and ‘sound alike’ results of healthcare professionals without the additional comprehensive matching and de-duplication component. Accordingly, the CRS would make no assumptions over matching or consolidating data, enabling the consumer to make judgements of the data based on their own knowledge of their healthcare professional.
CRS Request for Proposal (RFP)
Medicines Australia circulated a RFP to a select number of companies who specialise in the development and management of these type of databases. This RFP seeks responses against the revised CRS specifications and requires those companies to outline how they could develop a system that meets those requirements. Responses against this RFP were submitted by 6 companies on 10 November 2017. At the time of issuing this report, Medicines Australia is in the process of analysing the responses.
Learning from other countries
While Medicines Australia has elected to consider a more straightforward approach to achieve a CRS, we continue to engage with international counterparts to further develop our understanding of global transparency requirements. Medicines Australia will meet with representatives from the ABPI in mid-November 2017 to continue discussions and explore benefits derived and challenges experienced in the twelve months that its CRS has been in operation.
Third Transparency Reports
Considerable time and effort in the last six months has also been given to preparing the information for the third reports of information about reportable payments and transfers of value to individual healthcare professionals. The third reports, relating to activities occurring between 1 November 2016 and 30 April 2017, were published on 30 August 2017. Thirty-two member companies published reports on their company websites. These reports are hyperlinked on the Medicines Australia website.
The time period covered by the third report is the first full reporting period where healthcare professionals were no longer asked for their consent but instead operated under the reasonable expectations model of reporting. There were still a small number of activities reported in aggregate. This is due to healthcare professionals being engaged during the period of informed consent and not having given their approval for the information to be reported but the payment was nevertheless made during the last reporting period. It is expected that these aggregated figures will phase out over the coming reporting periods.
The work of Medicines Australia and its members in the six months to November 2017 demonstrates further progress in respect of the development of a CRS whilst delivering transparent reporting of payments and transfers of value to healthcare professionals for activities between November 2016 and April 2017.
Medicines Australia will analyse the responses to the RFP and evaluate options that may deliver the most appropriate solution for its membership.
16 November 2017
Downloadable PDF is also available.