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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.
Establishing a Centralised Reporting System
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 fifth progress report published in November 2017 we have undertaken the following work.
Medicines Australia issued a select competitive tender in November 2017 and received responses from six firms against the CRS specifications. Medicines Australia assessed each firm’s ability to develop a system that meets the specified requirements in a cost-effective manner. Particularly, Medicines Australia looked for a partner who proposed sufficient safeguards for data security, ensured on-shore data storage, and described an ability to scale for peak periods whilst maintaining the system between reporting periods.
Following this robust tender process, Medicines Australia recommended that the Medicines Australia Board approve the establishment of the CRS, and a recommended service provider which met these criteria be appointed. The Medicines Australia Board agreed with the recommendation in early April 2018.
The successful service provider, Pacific Commerce Pty Ltd, was recommended to the Board because they not only demonstrated they met the criteria described above, but could further enhance the system by providing their own secure data hosting facility in Sydney with the necessary infrastructure already in place, and proactive systems for monitoring, daily back up and solid rotation, and clearly defined response times for any critical issues. Pacific Commerce Pty Ltd also has experience working with Federal and State government health departments and related entities in the provision of similar data management and data analysis capabilities.
Once contracts are finalised, the development time for the CRS is estimated to be 8 weeks of build time. Additional time will be allocated for user acceptance (UAT) and experience (UX) testing. UAT and UX are important tasks in database development to ensure the robustness of the system and are especially critical in situations such as the CRS where personal information collected by member companies from individual healthcare professionals will be published.
During this development time, Medicines Australia will continue to work with its members on updating healthcare professional personal information collection statements.
New HCP payment and transfer of value information will not be included in the CRS unless healthcare professionals have received this updated notice which establishes the reasonable expectation that their data will be included. To assist informing healthcare professionals of the establishment of the CRS, Medicines Australia is writing to their representative organisations to advise them of the CRS’ implementation.
Fourth Transparency Reports
Medicines Australia continues to spend considerable time and effort in assisting and advising member companies in preparing the information about reportable payments and transfers of value to individual healthcare professionals. The fourth reports, relating to activities occurring between 1 May 2017 and 30 October 2017, were published by member companies on 28 February 2018. Thirty-three member companies published reports on their company websites. These reports are hyperlinked from the Medicines Australia website.
This was the second, full six month reporting period where healthcare professionals reasonably expected their data to be published. As anticipated, there were still a small number of activities reported in aggregate. This is due to there being some healthcare professionals who were engaged by companies before 1 October 2016 who had not given consent for their information to be reported but the relevant payment was made during the last reporting period (May to October 2017). It is expected that these aggregated data will continue to phase out over the coming reporting periods.
The work of Medicines Australia and its members in the six months to May 2018 demonstrates significant 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 May and October 2017.
Medicines Australia will work with its selected service provider to commence development of the CRS and testing that it meets all requirements prior to data being included or published by the system.
16 May 2018
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