SlideShare uma empresa Scribd logo
1 de 16
Baixar para ler offline
2010 European Trends
in Aggregate Spend,
Transparency, and Disclo-
sure
2010 European Trends
in Aggregate Spend,
Transparency, and Disclosure
November 2010
Exclusive Survey Results on
Life Sciences Industry
Regulatory Compliance
Trends...
COMPLY
e White Paper 3
Life Sciences companies across Europe are facing a
series of emerging global legislation and increased
regulatory enforcement, designed to prevent
corruption and bribery. But how well placed are these
organisations to comply with the need for improved
information transparency and aggregated healthcare
practitioner spend data? And how will the European
regulatory climate compare to the more mature U.S.
regulatory model?
Cegedim Relationship Management has undertaken
its first annual survey into pharmaceutical compliance
activity across Europe. The objective is to continuously
evaluate industry trends and best practices for
operational compliance.
The 2010 regulatory compliance survey reveals Life
Sciences companies across Europe are now very
aware that regulatory compliance and compliance
management is a challenge – a challenge that will
drastically change the way companies behave and
they way they interact with healthcare providers
and customers.
These organisations are also very aware that
compliance with new regulations, such as the UK
Anti-Bribery Act, will have a significant impact
on the industry’s image. Done well, regulatory
compliance should have a very positive effect on
image. However, if one company fails to step up
to the mark and receives high-profile fines, the
industry impact will be very detrimental. As a result,
organisations across the Life Sciences industry are
cooperating and collaborating to determine and
define the standards required.
These companies are certainly looking at the U.S.
regulatory market, with three quarters (75%) of the
respondents believing methods of tracking promotional
spending currently used in the U.S. will be deployed
in Europe. But while European regulators are closely
following the more mature U.S. model, the clear
cultural differences between Europe and the U.S. will
undoubtedly have an impact on the future regulations.
In the U.S., organisations must proactively disclose a
large amount of information; from violations to every
aspect of healthcare practitioner spend, under the
Sunshine Act that comes into effect in 2013, specific
to 2012 interactions with healthcare practitioners
and organizations.
This enforcement model reflects the high levels of
regulation and enforcement applied across every U.S.
industry, from finance to utilities. In Europe, however,
there is a far greater emphasis on self-policing. Life
Sciences companies are being asked by the authorities
to improve information transparency and provide
aggregated spend information. But, at the moment, the
final concept of transparency – and whether it will be
enforced – is still to be determined. However, there is no
doubt that the new regulatory requirements, at global,
regional and local levels will affect the way Life Sciences
companies do business; with 93% of respondents
agreeing that regulatory compliance will be a major
challenge in Europe.
Executive
Summary
93% agree that regulatory
compliance will be a major challenge
in Europe
White Paper4
7%
6%
8%
83%Pharmaceutical Company
Medical Device Company
Biotechnology Company
Other, Please Specify
There is little doubt that companies in the U.S. are
ahead of the regulatory curve – perhaps three to five
years ahead of their European counterparts. This
market has been highly regulated for several years, and
the forthcoming Sunshine Act includes even greater
demands for spend transparency. As a result, U.S. Life
Sciences companies are heavily focused on operational
compliance, working hard on the key issues of improving
data quality, meeting regulatory reporting requirements
and vendor management. As this data is compiled,
many are starting to leverage the insights from this
information to share across their organisations to
achieve productivity gains.
By contrast, in Europe, compliance officers are still
determining policy, assessing the implications of global,
regional and local regulatory requirements. Indeed, for
many companies, the process of creating a regulatory
compliance team is still in its infancy.
There are lessons that European companies can learn
from the U.S. that should streamline the regulatory
compliance process and drive down the cost of this
essential but non-core activity. Issues of data quality
remain a massive problem for U.S. Life Sciences
companies, despite the huge investment already made.
It is also important to gain business-wide involvement
in compliance activity – from senior management
commitment, to the IT team that must be involved in
executing the regulatory compliance programme and the
business people who own the data. Indeed, in the U.S.,
after several false starts, it has become apparent that
the most successful regulatory compliance programmes
are owned and driven by business people. Following this
model will help European Life Sciences companies reduce
time to market and the cost of regulatory compliance.
Furthermore, growing numbers of U.S. companies are
turning to dedicated third party solutions for support in
the compliance activity – with around 44% either already
using or planning to take this approach. This survey
reveals that European companies are beginning to follow
suit, although in much smaller numbers.
As the U.S. forges ahead with operational regulatory
compliance projects, it has become apparent that managing
the volume of regulatory change and reconciling diverse
data sources to deliver transparency, is too challenging
to handle internally. The use of third party providers is
becoming key in adhering to policies and procedures while
effectively tracking aggregate spend, identifying suspicious
financial transactions and streamlining regulatory
compliance monitoring.
But there is one area where Europe is already ahead of
the game, at a planning level at least, namely, leveraging
transparency and aggregate spend information to derive
benefits above and beyond compliance. 83% agree the
implementation of transparency guidelines will lead to
better resource allocation; whilst almost two thirds (62%)
agree implementation of transparency guidelines will
generate promotional spend decreases.
This first annual survey provides a fascinating insight into
the nascent regulatory landscape in Europe. It reveals
that Life Sciences companies are investing in regulatory
compliance and assessing policies and procedures. But
it also raises concerns about timing and the need to
extend monitoring beyond traditional sales and marketing
functions. With demands for information transparency
looming, Life Sciences organisations must now move
beyond the planning stage, consider every aspect of spend
and embark upon operational compliance programmes.
Figure 1 - Awareness of Regulatory Compliance Requirements
e White Paper 5
Regulatory compliance will grow as a strategic
challenge for the Life Sciences industry within the
next three years with the growing implementation
of new regulatory legislation and compliance
requirements:
93% of respondents agree that regulatory
compliance will be a major challenge in Europe.
Specifically, 82% believe that anti-corruption
regulation (Foreign Corrupt Practices Act, UK
Anti-Bribery Law) will impact the regulatory
environment and global transparency
requirements.
Almost two thirds (62%) agree that the
implementation of transparency guidelines will
generate promotional spend decreases.
The European compliance function is mostly
focused on high-level compliance governance
design and validation – as opposed to the U.S.,
where compliance is being implemented at an
operational level, with an emphasis on data,
reporting and vendor management
The U.S. transparency and aggregate spend model
is likely to spread across Europe, leading to an
increase in companies’ investments
Over half (53%) of respondents anticipate their
investment in aggregate spend transparency to
grow.
Data identification, consistency and quality are
the major challenges in project implementation and
compliance governance processes
22% of companies in Europe are using Excel
today to monitor expenditure. This is set to
drop to 10% as organisations increase their
dependency on third party solutions to meet
compliance requirements.
Organisations in Europe are looking to exploit
greater information transparency to derive further
benefits beyond compliance:
83% agree the implementation of transparency
guidelines will lead to better resource allocation
Key Findings
6%
73%
22%
5%
Somewhat informed
Not at all informed
Very well informed
40%
38%
49%
36%26%
53%
47%
44%
Implementation of transparency guidelines will lead to a better resource allocation.
Regulatory compliance will be a major challenge in Europe.
Completely Agree Mostly Agree
Implementation of transparency guidelines will generate promotional spend decreases.
Regulatory compliance environment will have a major impact on the Life Science industry image.
Figure 2 - Awareness of Regulatory Compliance Requirements Figure 3 - Regulatory Compliance Outlook
White Paper6
Whether or not it was merited, there can be no
argument that Life Sciences organisations are now
firmly in the spotlight of anti-corruption and anti-
bribery officials. Global polices regulating promotional
expenditure and sample distributions are being
reinforced, whilst in the U.S. Life Sciences companies
have experienced both dawn raids and serious
investigations by the Department of Justice.
And the implications are significant; pharmaceutical
and medical device companies can face both civil
and criminal sanctions. Siemens was recently fined
more than $1 billion for not maintaining accurate
books of records, while individual executives from
well-established international companies are being
prosecuted for not having implemented enough internal
control and validation measures.
Furthermore, the series of legislation facing Life
Sciences companies continues to grow. The recently
revisited UK Anti Bribery Act comes into force in April
2011 and adds even more complexity to the existing
Foreign Corrupt Practices Act (FCPA), the Organisation
for Economic Co-operation and Development (OECD)
Convention and the Sunshine Act due to come into
force in the U.S. in 2013.
But just how geared up are European Life Sciences
companies for this new regulatory intensity? In the
first annual compliance survey conducted by Cegedim
Relationship Management, the results revealed
some awareness (95%) of the growing regulatory
compliance requirement and the majority (73%) are
very well informed.
Meanwhile, over eight out of ten respondents (82%)
believe the coming anti-corruption regulations, such
as the FCPA and UK Anti-Bribery Law will highly (38%)
or somewhat (44%) impact the regulatory environment.
Less than two out of ten (16%) feel that there will be
low or no impact.
But understanding the extent of that impact remains
a challenge. European Life Sciences companies do
not necessarily want to follow the U.S. route which
will require companies to publish online all spend to
healthcare professionals - both direct and indirect.
This highly-enforced regulatory environment does
not fit comfortably with the European culture of
self-regulation.
However, European regulators are currently looking
closely at the U.S. model to determine the right route
forward and three quarters (75%) of the respondents
believe that methods of tracking promotional
spending currently used in the U.S. will eventually
be deployed across Europe. Approximately one-half
(47%) believe that they will probably come; around
one-quarter (28%) believe that they are likely to
come. And just one in ten (10%) believe that they are
not coming.
Certainly organisations are aware of the implications
of escalating compliance demands. 93% of respondents
agreed that regulatory compliance will be a major
challenge in Europe; and 93% also say the regulatory
Introduction
82% believe the coming
corruption regulations will impact the
regulatory environment
e White Paper 7
compliance environment will have a major impact on
the Life Sciences industry image.
However, it is apparent that despite well-publicised
regulatory compliance recruitment programmes, the
responsibility for compliance in Europe still rests
primarily with sales and marketing teams. 117
individuals contributed to the research; 83% of these
were from pharmaceutical, 8% medical device and 6%
biotechnology companies.
Just 26% of respondents, however, have a
dedicated regulatory compliance role; while 29%
are in marketing and 18% in sales. In contrast in
the U.S., 32% of respondents were in compliance
and 21% in operations; just 14% were in marketing
and 13% in sales.
However, it is good to note that in the European
research, 7% are in general management; 5% in
finance/audit; 4% in public/government affairs
and 4% in medical, demonstrating the growing
realisation that compliance must become a part
of the daily business life across every part of the
pharmaceutical organisation.
The emphasis on sales and marketing personnel
taking control of regulatory compliance requirements
also reflects the fact that the European marketplace
is still focused heavily on tracking sales and
marketing spend to healthcare professionals rather
than every aspect of spend, such as support for
clinical trials which also will demand input from R&D
and public affairs.
Furthermore, while the majority (88%) of these
individuals have a direct involvement in mandate
marketing and promotional spend laws, only 51% are
very involved in healthcare professionals
spend tracking and monitoring process based
on existing laws and legislations. In the U.S., by
comparison, 69% of respondents were very involved
in spend tracking and monitoring. No doubt the
level of European involvement will increase as the
compliance function in Europe becomes more mature.
29%
26%
18%
7%
5%
4%
4%
3%
2%
2%
10%
Marketing
Compliance
Sales
Management (General)
Finance/Audit
Public/Government Affairs
Medical
Legal
Technical Operations (IS)
R&D
Other
Figure 4 - Report Participant Demographics
White Paper8
Understanding
Compliance
So how confident are these organisations in achieving
fast emerging regulatory compliance demands?
According to the research, almost three-quarters
(73%) of the respondents say that their company is
either excellently (31%) or well equipped (42%) to
comply with transparency regulations as they exist
today. Just one quarter (25%) feels that their company
is fairly (22%) or poorly (3%) equipped to deal with
transparency regulations.
This compares with just 29% of companies in the U.S.
believing the organisation is either excellently or well
equipped to comply. This clearly reflects the different
levels of maturity in the U.S. and the very strong culture
of enforcement: in the U.S., organisations have to
demonstrate regulatory compliance to what are far more
stringent regulations that span the entire organisation,
not just the sales and marketing role; whilst in Europe
there are, as yet, no best practice guidelines or
benchmarks for regulatory compliance activity.
Given that far more stringent regulations are expected
in Europe shortly, the results suggest a worrying level
of complacency amongst organisations. And those
that only rate their ability to comply as ‘fair’ today, in
what is a relatively unregulated environment, should
be particularly concerned about how they will address
compliance at global, regional and local levels over the
coming 12-18 months.
The research also revealed that organisations are
still developing strategies to deliver effective
transparency projects. Indeed, when asked to
describe their role in the company’s involvement with
locally-mandated marketing and promotional spend
compliance, the majority of respondents (60%) said
they were directly involved with process design and
implementation.
Approximately four out of ten are involved with data
analysis (44%) and report review and approval (39%);
approximately three out of ten are involved with
tracking legislative updates (30%) and gathering and/
or entering of data (25%); while approximately two in
ten are involved in report generation (19%), processing
data (18%), vendor selection (16%) and vendor
management (15%).
In contrast, U.S. Life Sciences companies are three
to five years ahead with the implementation of
operational-based compliance solutions, with a far
higher emphasis on areas such as data processing,
report generation and vendor selection.
It is understandable that these European organisations
are focusing attention on understanding the regulatory
compliance requirements, particularly since local
and regional interpretations of regulations vary. The
differences can range from not bribing “public officials”
– a term that itself can be interpreted differently
across the globe depending on the way health services
are delivered; to the new Anti-Bribery Law that
includes both private and public Healthcare sectors in
the UK. This law also has far tougher sanctions than
other legislation: an individual convicted for failing
to implement adequate measures now faces up to 10
years in prison and unlimited fines.
U.S. Life Sciences companies are
three to five years ahead with the
implementation of operational-base
compliance solutions
e White Paper 9
Furthermore, each country has a different limit for the
amount of promotional spend allowed per official – for
example, small gifts cannot exceed £6 in the UK, but
€30 in Spain or 100 zloty in Poland. And even the use
of samples is significantly reduced, with organisations
now complying with the ‘four times two’ standards
– no more than four samples per physician for two
years after the product’s launch – laid down by the
European Federation of Pharmaceutical Industries and
Associations (EFPIA).
Despite this complexity, the survey highlighted
opportunities associated with compliance activity
– most notably the value of creating and providing
aggregated spend information to the business as
a whole. Some 83% agree the implementation of
transparency guidelines will lead to better resource
allocation; while almost two thirds (62%) agree
implementation of transparency guidelines will
generate promotional spend decreases.
These figures make it clear that organisations
across Europe are already looking to derive benefits
beyond compliance from this investment by better
understanding the deployment of resources in terms of
both people and investment. This contrasts heavily to
the U.S. where there has traditionally been a clear line
between compliance and the business: organisations
in the U.S. are only now beginning to look at attaining
possible business benefits from regulatory compliance
data. The business-based attitude of the European
market should enable companies not only to embed
compliance activity in every part of the organisation
but also derive additional benefits faster.
3%
22%
42%
31%Excellent
Good
Fair
Poor
Figure 5. Ability for Company to Comply with Transparency Regulations Today
White Paper10
Given the awareness of the importance of regulatory
compliance activity to the Life Sciences industry, just
how committed are these organisations to investing in
the right people, processes and technologies to drive
successful compliance programmes?
Over half (53%) of respondents anticipate their investment
in solution and resources to provide aggregate spend
transparency to grow, reflecting the growing awareness of
the compliance risk across both the industry and Europe.
And of the 40% that expect investment to stay the same,
the majority of respondents are in country-based, rather
than regional roles revealing a gap between local and
regional compliance understanding.
So how will this investment be made? Today over half
(56%) are using internal software systems to monitor
company expenditure in Europe; and 22% are reliant
on manual processes and Excel spreadsheets; with just
10% using a dedicated third party solution. When asked
how the company planned to satisfy spend transparency
requirements tomorrow, there is a significant shift away
from manual processes. Indeed, just 10% plan to use
Excel in the future. Instead, 56% will use internal software
systems; and 19% will use third party solutions.
Given the comparative sophistication of the U.S.
marketplace, it is interesting to see how attitudes to
monitoring aggregate spend compare. Today in the
U.S., some 40% are still reliant on Excel, 32% use
internal software systems, 24% third party solutions
and 4% do not monitor at all. In the future, the
majority (44%) plan to adopt dedicated third party
software; 31% will use internal software systems, while
17% plan to remain with Excel.
Certainly this shift away from manual processes is
critical. The new regulatory implications extend far
beyond traditional detailing activity and embrace
every part of the organisation that has any kind of
customer interaction, from engaging with customers
in clinical trials, to providing grants to physicians or
simply inviting a Key Opinion Leader to a progress
meeting. Also companies will have to include all
payments made on their behalf by external partners
and third parties companies.
Therefore, pharmaceutical companies now need to
track every interaction and financial transaction,
monitor both direct and indirect payments undertaken
on behalf of the organisation, and then reconcile the
expenses to each physician or official.
This process becomes even more complex when
considering the multi-national nature of most Life
Achieving
Compliance
Figure 6. Anticipation of Level of Investment on
Aggregate Spend Level for Next Year
3%
11%
40%
42%Increase
Stay the same
Significant increase
Decrease
83% Agree the
implementation of transparency
guidelines will lead to better resource
allocation
e White Paper 11
Sciences company operations: organisations have to
put in place global guidelines and consistent standards
to monitor closely all interactions with healthcare
professionals. They have to be able to reflect the
different regulations in each country; and they need
to achieve this without incurring an unmanageable,
expensive overhead.
This huge shift towards third party software, especially
in the U.S., is a clear indication of the need for support
in designing and implementing robust processes for
creating aggregated spend data that encompasses more
than just sales and marketing expenditures.
In Europe, Customer Relationship Management (CRM)
provides companies with an easy route to collate the
sales and marketing aspect of spend information.
The significant numbers of organisations looking to
adopt third party solutions in the U.S. demonstrates
recognition that when organisations have to include
information from R&D, medical affairs and third party
vendors, there is a need for external support in areas
such as data management and aggregation. As the
compliance model in Europe becomes more mature,
it is very likely the same patterns of third party
software adoption will be followed.
And a fundamental component of this process is the
creation of a unique customer record – a problem that
has been extremely understated, even in the mature
U.S. market. Pulling information from multiple, diverse
systems - from ERP to third party vendors - and
ensuring spend is reconciled to a single, accurately
identified customer, is a significant challenge. Customer
data will be often incomplete and recorded differently
in each system. How can an organisation ensure that
Dr. Brown is the same Dr. Patrick Brown, or hospital
consultant Pat Brown in Manchester?
U.S. companies are investing heavily in creating
excellent customer Master Data Management (MDM)
systems, the core component of the transparency
process. Yet just 15% of U.S. companies are very
confident in the ability of the internal customer MDM
system to define the unique recipient records across all
spend sources; with 31% somewhat confident.
In Europe, by contrast, where organisations have yet
to embark upon the creation of MDM, one quarter
(25%) of respondents are very confident in the ability
of internal systems to define the unique recipient
record across spend sources or across countries;
while 37% are only somewhat confident. Again, this
difference reflects the sales and marketing emphasis
of the European compliance activity to date, with
companies reliant upon and confident in the quality
of their CRM systems.
However, true transparency will require cross-system
information provision and failure to define the unique
recipient (customer) record across all spend sources or
across countries will lead to the failure of the entire
compliance project.
Figure 7. Functions to Ensure Compliance with Local Mandated Marketing and Promotional Spend Regulation
60%
44%
39%
30%
25%
19%
18%
16%
15%
13%
Process design and implementation
Data Analysis
Report review and approval
Tracking legislative updates
Gathering and/or entry of data
Report generation
Processing data
Vendor selection
Vendor management
Other, please specify
White Paper12
Data Challenge
This issue is reflected in the concerns raised in
response to complying with FCPA and regulations
such as the OECD convention and UK Anti-Bribery.
The greatest concern is collecting all relevant spend
data (39%), followed by data integrity (36%) and
identification of spend recipients (36%) and preparing
reports for data disclosure (34%).
Given that Life Sciences companies in Europe will
have to report accurately on this data within the
next 12-18 months notably in the U.S. and UK, it
is clear that organisations must focus hard up-
front on enhancing data management governance
before embarking upon any further regulatory
compliance activity.
However, when asked ‘what are the key issues that
impact the level of regulatory compliance,’ organisations
cited lack of understanding of policy (62%) as the
primary impact. Lack of policy knowledge leads to errors
in data, therefore organisations need to embark upon
company-wide education and training programmes to
reinforce the importance of compliance and FCPA to the
pharmaceutical business – and the market as a whole.
It is no surprise that poor record keeping or data entry
errors is the next most significant impact (54%), given
the need for high quality data to achieve compliance;
if individuals do not understand the policies and
procedures, or recognise the need for ethical
behaviour, poor record keeping and data errors will be
inevitable. Improving education should, by default, lead
to better information.
The third most important impact is system process
shortcomings (52%).  But as the need for a unified,
strategic global compliance strategy and view becomes
more important, the shortcomings of existing systems
for monitoring and reporting aggregate spend will
become even more evident.
The way in which information is captured is just half
the problem.  In the U.S. just 37% of respondents
indicate that their company enforces corporate
standards for healthcare professional and spend data
capture which applies to all suppliers and staff. The
remaining respondents either do not have standards or
have standards which are not used universally.
In Europe, however, where the market is significantly
less regulated, some 83% of organisations enforce
corporate standards for healthcare professionals and
Figure 8. Areas of Concern Complying with the FCPA and Anti-Corruption Regulations
36%
39%
36%
34%
30%Handling inquiries after spend is posted
Prepare reports and analysis for potential data disclosure
Proper identification of spend recipients
Data Integrity - having accurate, certified, complete,
and timely data
Collecting all relevant spend data
e White Paper 13
spend data capture. The majority (62%) have standards
that apply to all external parties and internal data;
whilst only 21% have standards that only apply to
some external parties and internal data. Just 7% of
organisations currently have no standards and are not
in the process of defining any.
Where enforced, these standards apply to
honorarium fees (71%); promotional spend (75%) and
consultancy fees (68%). Third party data (38%) is
less commonly covered.
These figures are very revealing. The strong
emphasis on sales and marketing related spend
underlines the relative immaturity of the European
market when compared to the U.S. – and reflects the
very different enforcement models applied in these
markets. 
The challenges associated with collecting and collating
this data reflect the problems already encountered in
the U.S.; issues include managing disparate formats
and standards (37% challenging) and establishing
unique identification of healthcare professional from all
the expense data sources (35% challenging), identifying
all data sources (32%) and managing incomplete spend
information (31%).
 
The implications of these problems are significant.
A lack of consolidated customer view created by the
inability to uniquely identify a healthcare professional
from diverse expense data sources will lead to
inaccurate monitoring and reporting, and a risk
of compliance breach. But with multiple source
systems and owners, file format differences and
numerous third party sources, even identifying all
the sources before creating the unique customer
number is a massive challenge. Add in global
regulatory compliance needs and the complexity
increases significantly
Figure 9. Does your Company Enforce Corporate Standards for Healthcare Professionals and Spend Data Capture
Figure 10. How Challenging are the Following Processes?
3%
7%
21%
62%Yes, applies to all the external
and internal data
Yes, but applies only to external
partners and
internal systems
No, we do not have standards
No, but we are in the process
of defining one
0%
No, looking for a vendor
to provide a solution
31%
32%
35%
37%Managing disparate formats
and standards
Matching and establishing
unique identification of a
Healtcare Professional from
all the expense data sources
Identifying all data sources
Managing incomplete spend
and customer information
White Paper14
Robust Model
If organisations are to achieve a consistent, global
model for regulatory compliance, it is essential to
create a standard data capture model that also
supports local rules to ensure every market is managed
consistently and effectively. As a dire imperative,
organisations need to consider not only spend
aggregation but also robust and thorough customer
data management.
One option is to put in place an aggregate spend
solution that builds on existing Key Account
Management (KAM) information to automate and
streamline regulatory compliance monitoring and
reporting. It is by leveraging this strong, accurate
data source and integrating a wide range of
enterprise applications for Sales Force Automation,
ERP, Finance and HR, that organisations can
streamline and automate the process of highlighting
suspicious transactions.
Using Business Intelligence, Life Sciences companies
can not only conduct the required in-depth historic
analysis but also put in place proactive alerts both
for individuals identified as highly influential and also
if payments to specific practitioners are about to hit
the threshold (Fair Market Value); preventing both
intentional and accidental compliance breaches.
There is a further component to compliance activity,
namely transparency. In this global operating
environment organisations are increasingly looking
at opportunities to drive best practice, create global
policies with local implementation and improve
processes and key to this is to improve transparency.
This regulatory compliance drive is now enabling
organisations to collect and share information not only
with government and regulators but also internally.
Indeed, the wealth of financial information collected
to achieve compliance provides valuable insight into
cross-organisational spend with specific healthcare
providers. Adding customer data management to the
process provides a depth of information that can
be analysed to assess value, understand how much
is being spent at an individual level and improve
resource allocation.
This improved insight also has implications for Key
Account Managers. The aggregate spend information
can be analysed to provide a Key Account Manager
with insight into spend at a local level, such as
investment in training or continuous medical education
(CME) to a physician. With a complete picture of the
investment by organisation, a Key Account Manager
embarking upon negotiation for a new bid or new
customer is in a far stronger position to demonstrate
the value being provided by the Life Sciences company.
This is a powerful tool that, if used correctly, should
have a direct, bottom line impact on business.
Using Business Intelligence,
companies… can put in place
pro-active alerts. Preventing
both intentional and accidental
compliance breaches
e White Paper 15
Conclusion
Transforming the image of the Life Sciences
industry will take time. But the commitment being
demonstrated today is extremely positive. And
whilst organisations are obviously keen to avoid the
negative publicity, fines and possible court cases
associated with bribery and corruption, there is no
doubt that organisations in Europe are also looking to
derive benefits from improved transparency, whether
for internal compliance reasons or external disclosure.
With a real opportunity for a Life Sciences company
to establish a good image to the healthcare market,
the industry is increasingly considering transparency
as a huge competitive advantage and benefit, and
an opportunity to improve resource utilisation,
rather than simply an expensive and time-consuming
overhead expense.
But, while the commitment is not in doubt,
organisations are still struggling to actually deliver
transparency, both from a technology and business
model perspective. This is a multi-disciplinary project
that is not just about exploiting technology but also
about driving new behaviour change and imposing
compliance as a change in ethical behaviour to the
customer.
Critically, global regulatory compliance and
transparency demands an automated and streamlined
solution: not only are the costs of a manual or
spreadsheet approach too high, but without some
kind of automation and built-in alerts that reflect the
different countries’ interpretations, organisations will
be exposed to a high risk of compliance breach.
Regulatory compliance is becoming a key function
within the Life Sciences business; indeed it is, in
some companies, becoming a cornerstone of how
business is conducted and is massively influencing
the commercial model. But for the industry to achieve
wholesale changes in attitude and perception, every
organisation needs to commit. Without that, European
Life Sciences companies will face the highly enforced
model being adopted in the U.S., rather than a self-
policing approach – a model that many fear will
significantly undermine customer relationships.
Now is the time to work with other organisations in
the field to develop best practices, to assess how
to best leverage existing spend capture sources
and resources, and to put in place procedures and
practices that will mitigate both the risk and cost
associated with global compliance.
Authored by;
Bill Buzzeo
VP and GM of Global Compliance Solutions
Cegedim Relationship Management
william.buzzeo@cegedim.com
Guillaume Roussel
VP Compliance Solutions EMEA
Cegedim Relationship Management
guillaume.roussel@cegedim.com
Exclusive Survey Results on
Life Sciences Industry
Regulatory Compliance
Trends...
COMPLY
Reproduction and distribution of this report is allowed only with the
written authorisation from Cegedim.
White Paper16
2010 European Trends
in Aggregate Spend,
Transparency, and Disclosure
For more information, please contact
compliance@cegedim.com
www.cegedim.com/eucompliance
2010 Cegedim, Inc. All Rights Reserved
Reproduction and distribution of this report is allowed only with the written authorisation from Cegedim.White Paper16
2010 European Trends
in Aggregate Spend,
Transparency, and Disclosure
For more information, please contact
compliance@cegedim.com
www.cegedim.com/eucompliance
2010 Cegedim, Inc. All Rights Reserved
Reproduction and distribution of this report is allowed only with the written authorisation from Cegedim.

Mais conteúdo relacionado

Mais procurados

What does the EU Non-Financial Reporting Directive mean for you?
What does the EU Non-Financial Reporting Directive mean for you?What does the EU Non-Financial Reporting Directive mean for you?
What does the EU Non-Financial Reporting Directive mean for you?FrameworkESG
 
Medical Cost Trend: Behind the Numbers 2017
Medical Cost Trend: Behind the Numbers 2017Medical Cost Trend: Behind the Numbers 2017
Medical Cost Trend: Behind the Numbers 2017PwC
 
Amgen Cowen and Company 37th Annual Health Care Conference Presentation
Amgen Cowen and Company 37th Annual Health Care Conference PresentationAmgen Cowen and Company 37th Annual Health Care Conference Presentation
Amgen Cowen and Company 37th Annual Health Care Conference PresentationThe ScientifiK
 
Magellan Strategies EPA Regulation Survey Press Release 061214
Magellan Strategies EPA Regulation Survey Press Release 061214Magellan Strategies EPA Regulation Survey Press Release 061214
Magellan Strategies EPA Regulation Survey Press Release 061214Magellan Strategies
 
Pitch deck mobiome
Pitch deck   mobiome Pitch deck   mobiome
Pitch deck mobiome Ike Ekeh
 
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey report
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey reportChina Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey report
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey reportFranck Le Deu
 
State of Business Networks in Process Industries 2014 - Summary Charts
State of Business Networks in Process Industries 2014 - Summary ChartsState of Business Networks in Process Industries 2014 - Summary Charts
State of Business Networks in Process Industries 2014 - Summary ChartsLora Cecere
 
3rd corporate compliance & transparency in pharma
3rd corporate compliance & transparency in pharma3rd corporate compliance & transparency in pharma
3rd corporate compliance & transparency in pharmaMarket iT
 
Research aarkstoreenterprise bioinformatics partnering terms & agreements
Research aarkstoreenterprise bioinformatics partnering terms & agreementsResearch aarkstoreenterprise bioinformatics partnering terms & agreements
Research aarkstoreenterprise bioinformatics partnering terms & agreementsNeel Terde
 
Risks of Open Payments and Medicare Part D Data
Risks of Open Payments and Medicare Part D DataRisks of Open Payments and Medicare Part D Data
Risks of Open Payments and Medicare Part D Dataqordata
 
John Soloninka
John SoloninkaJohn Soloninka
John Soloninkaichil
 
Managing The Risk of Open Payments - Validate Spend Report Before CMS Submission
Managing The Risk of Open Payments - Validate Spend Report Before CMS SubmissionManaging The Risk of Open Payments - Validate Spend Report Before CMS Submission
Managing The Risk of Open Payments - Validate Spend Report Before CMS Submissionqordata
 
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...Visiongain
 

Mais procurados (20)

What does the EU Non-Financial Reporting Directive mean for you?
What does the EU Non-Financial Reporting Directive mean for you?What does the EU Non-Financial Reporting Directive mean for you?
What does the EU Non-Financial Reporting Directive mean for you?
 
AMGEN Financial Analysis
AMGEN Financial AnalysisAMGEN Financial Analysis
AMGEN Financial Analysis
 
Medical Cost Trend: Behind the Numbers 2017
Medical Cost Trend: Behind the Numbers 2017Medical Cost Trend: Behind the Numbers 2017
Medical Cost Trend: Behind the Numbers 2017
 
Amgen Cowen and Company 37th Annual Health Care Conference Presentation
Amgen Cowen and Company 37th Annual Health Care Conference PresentationAmgen Cowen and Company 37th Annual Health Care Conference Presentation
Amgen Cowen and Company 37th Annual Health Care Conference Presentation
 
Magellan Strategies EPA Regulation Survey Press Release 061214
Magellan Strategies EPA Regulation Survey Press Release 061214Magellan Strategies EPA Regulation Survey Press Release 061214
Magellan Strategies EPA Regulation Survey Press Release 061214
 
AMGEN ACC 2017
AMGEN ACC 2017  AMGEN ACC 2017
AMGEN ACC 2017
 
Pitch deck mobiome
Pitch deck   mobiome Pitch deck   mobiome
Pitch deck mobiome
 
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey report
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey reportChina Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey report
China Pharmaceuticals - Building Bridges to Innovation - 2015 McKinsey report
 
State of Business Networks in Process Industries 2014 - Summary Charts
State of Business Networks in Process Industries 2014 - Summary ChartsState of Business Networks in Process Industries 2014 - Summary Charts
State of Business Networks in Process Industries 2014 - Summary Charts
 
3rd corporate compliance & transparency in pharma
3rd corporate compliance & transparency in pharma3rd corporate compliance & transparency in pharma
3rd corporate compliance & transparency in pharma
 
Research aarkstoreenterprise bioinformatics partnering terms & agreements
Research aarkstoreenterprise bioinformatics partnering terms & agreementsResearch aarkstoreenterprise bioinformatics partnering terms & agreements
Research aarkstoreenterprise bioinformatics partnering terms & agreements
 
B-School Job Market at a Glance
B-School Job Market at a GlanceB-School Job Market at a Glance
B-School Job Market at a Glance
 
Optimize apr13pres
Optimize apr13presOptimize apr13pres
Optimize apr13pres
 
Risks of Open Payments and Medicare Part D Data
Risks of Open Payments and Medicare Part D DataRisks of Open Payments and Medicare Part D Data
Risks of Open Payments and Medicare Part D Data
 
Presentation
PresentationPresentation
Presentation
 
John Soloninka
John SoloninkaJohn Soloninka
John Soloninka
 
Managing The Risk of Open Payments - Validate Spend Report Before CMS Submission
Managing The Risk of Open Payments - Validate Spend Report Before CMS SubmissionManaging The Risk of Open Payments - Validate Spend Report Before CMS Submission
Managing The Risk of Open Payments - Validate Spend Report Before CMS Submission
 
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...
Clinical Trial Supply and Logistics Market for Pharma 2018-2028 pharmaceutica...
 
Occupational Health and Safety Outlook 2018
Occupational Health and Safety Outlook 2018Occupational Health and Safety Outlook 2018
Occupational Health and Safety Outlook 2018
 
Medtronic case ppt
Medtronic case pptMedtronic case ppt
Medtronic case ppt
 

Semelhante a 2010 european trends in aggregate spend, transparency and disclosure

Cloud Enabled Pharma R&D Trials
Cloud Enabled Pharma R&D TrialsCloud Enabled Pharma R&D Trials
Cloud Enabled Pharma R&D TrialsDmitriy Synyak
 
Recruiting Retaining a Competitive Workforce
Recruiting Retaining a Competitive WorkforceRecruiting Retaining a Competitive Workforce
Recruiting Retaining a Competitive WorkforceMark AJ Smith
 
Medical Devices: Equipped for the Future?
Medical Devices: Equipped for the Future?Medical Devices: Equipped for the Future?
Medical Devices: Equipped for the Future?Revital (Tali) Hirsch
 
Medical devices equipped for the future
Medical devices equipped for the futureMedical devices equipped for the future
Medical devices equipped for the futureBrand Acumen
 
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...Sam Botting
 
EAI Compliance Infographic
EAI Compliance InfographicEAI Compliance Infographic
EAI Compliance InfographicIdeba
 
Global Pharma report 2014
Global Pharma report 2014Global Pharma report 2014
Global Pharma report 2014Georgi Daskalov
 
Creating a roadmap to clinical trial efficiency
Creating a roadmap to clinical trial efficiencyCreating a roadmap to clinical trial efficiency
Creating a roadmap to clinical trial efficiencySubhash Chandra
 
The Pharma & ACO Relationship
The Pharma & ACO RelationshipThe Pharma & ACO Relationship
The Pharma & ACO RelationshipJoseph Gaspero
 
Regulatory Affairs at PLG
Regulatory Affairs at PLGRegulatory Affairs at PLG
Regulatory Affairs at PLGAlison Fautré
 
The State of Logistics Outsourcing; 2008 Third Party Logistics Study
The State of Logistics Outsourcing; 2008 Third Party Logistics StudyThe State of Logistics Outsourcing; 2008 Third Party Logistics Study
The State of Logistics Outsourcing; 2008 Third Party Logistics StudyDennis Wereldsma
 
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)eDetailing: A Strategic Analysis Of Implementation And ROI (mini)
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)Eularis
 
Serialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceSerialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceCognizant
 
Serialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceSerialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceCognizant
 
RegulatoryScreening_short_guide
RegulatoryScreening_short_guideRegulatoryScreening_short_guide
RegulatoryScreening_short_guideViola Peter
 
Progressions_2011_Final_021011
Progressions_2011_Final_021011Progressions_2011_Final_021011
Progressions_2011_Final_021011Gautam Jaggi
 

Semelhante a 2010 european trends in aggregate spend, transparency and disclosure (20)

Cloud Enabled Pharma R&D Trials
Cloud Enabled Pharma R&D TrialsCloud Enabled Pharma R&D Trials
Cloud Enabled Pharma R&D Trials
 
Recruiting Retaining a Competitive Workforce
Recruiting Retaining a Competitive WorkforceRecruiting Retaining a Competitive Workforce
Recruiting Retaining a Competitive Workforce
 
Medical Devices: Equipped for the Future?
Medical Devices: Equipped for the Future?Medical Devices: Equipped for the Future?
Medical Devices: Equipped for the Future?
 
Medical devices equipped for the future
Medical devices equipped for the futureMedical devices equipped for the future
Medical devices equipped for the future
 
HTA Uncovered february 2014
HTA Uncovered february 2014HTA Uncovered february 2014
HTA Uncovered february 2014
 
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...
Group 2 Module 5 Project - Small devices, BIG impact. How wearable health dev...
 
EAI Compliance Infographic
EAI Compliance InfographicEAI Compliance Infographic
EAI Compliance Infographic
 
EAI Compliance Infographic
EAI Compliance InfographicEAI Compliance Infographic
EAI Compliance Infographic
 
Global Pharma report 2014
Global Pharma report 2014Global Pharma report 2014
Global Pharma report 2014
 
Creating a roadmap to clinical trial efficiency
Creating a roadmap to clinical trial efficiencyCreating a roadmap to clinical trial efficiency
Creating a roadmap to clinical trial efficiency
 
Beyond borders
Beyond bordersBeyond borders
Beyond borders
 
The Pharma & ACO Relationship
The Pharma & ACO RelationshipThe Pharma & ACO Relationship
The Pharma & ACO Relationship
 
Regulatory Affairs at PLG
Regulatory Affairs at PLGRegulatory Affairs at PLG
Regulatory Affairs at PLG
 
The State of Logistics Outsourcing; 2008 Third Party Logistics Study
The State of Logistics Outsourcing; 2008 Third Party Logistics StudyThe State of Logistics Outsourcing; 2008 Third Party Logistics Study
The State of Logistics Outsourcing; 2008 Third Party Logistics Study
 
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)eDetailing: A Strategic Analysis Of Implementation And ROI (mini)
eDetailing: A Strategic Analysis Of Implementation And ROI (mini)
 
Serialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceSerialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond Compliance
 
Serialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond ComplianceSerialization: Driving Business Value Beyond Compliance
Serialization: Driving Business Value Beyond Compliance
 
RegulatoryScreening_short_guide
RegulatoryScreening_short_guideRegulatoryScreening_short_guide
RegulatoryScreening_short_guide
 
Progressions_2011_Final_021011
Progressions_2011_Final_021011Progressions_2011_Final_021011
Progressions_2011_Final_021011
 
Pwc gdpr survey 2018
Pwc gdpr survey 2018Pwc gdpr survey 2018
Pwc gdpr survey 2018
 

Mais de Óscar Miranda

Us tmt social software for business_031011
Us tmt  social software for business_031011Us tmt  social software for business_031011
Us tmt social software for business_031011Óscar Miranda
 
Us tmt social software for business_031011
Us tmt  social software for business_031011Us tmt  social software for business_031011
Us tmt social software for business_031011Óscar Miranda
 
2010 internet use_trends
2010 internet use_trends2010 internet use_trends
2010 internet use_trendsÓscar Miranda
 
2010 internet use_analysis
2010 internet use_analysis2010 internet use_analysis
2010 internet use_analysisÓscar Miranda
 
Redes socialesops v230211 Latinoamerica
Redes socialesops v230211 LatinoamericaRedes socialesops v230211 Latinoamerica
Redes socialesops v230211 LatinoamericaÓscar Miranda
 
Az social media_white_paper
Az social media_white_paperAz social media_white_paper
Az social media_white_paperÓscar Miranda
 
La Sociedad de la Información, Telefónica 2010
La Sociedad de la Información, Telefónica 2010La Sociedad de la Información, Telefónica 2010
La Sociedad de la Información, Telefónica 2010Óscar Miranda
 
Izo twitter-engage-01-2011
Izo twitter-engage-01-2011Izo twitter-engage-01-2011
Izo twitter-engage-01-2011Óscar Miranda
 
Leveraging social media for pharmaceutical companies
Leveraging social media for pharmaceutical companiesLeveraging social media for pharmaceutical companies
Leveraging social media for pharmaceutical companiesÓscar Miranda
 
Sanidad pacientes web_2_0
Sanidad pacientes web_2_0Sanidad pacientes web_2_0
Sanidad pacientes web_2_0Óscar Miranda
 
Ifhp price report2010_comparativepricereport29112010
Ifhp price report2010_comparativepricereport29112010Ifhp price report2010_comparativepricereport29112010
Ifhp price report2010_comparativepricereport29112010Óscar Miranda
 
Informe Farmaindustria 2009
Informe Farmaindustria 2009Informe Farmaindustria 2009
Informe Farmaindustria 2009Óscar Miranda
 
informe biocat_2009_es
informe biocat_2009_esinforme biocat_2009_es
informe biocat_2009_esÓscar Miranda
 
Valoracion financiacion gasto sanitario Fundación BBVA
Valoracion financiacion gasto sanitario Fundación BBVAValoracion financiacion gasto sanitario Fundación BBVA
Valoracion financiacion gasto sanitario Fundación BBVAÓscar Miranda
 
Informe sectorial 2010 sanidad
Informe sectorial 2010   sanidadInforme sectorial 2010   sanidad
Informe sectorial 2010 sanidadÓscar Miranda
 

Mais de Óscar Miranda (20)

Bcg espanaconecta
Bcg espanaconectaBcg espanaconecta
Bcg espanaconecta
 
Us tmt social software for business_031011
Us tmt  social software for business_031011Us tmt  social software for business_031011
Us tmt social software for business_031011
 
Us tmt social software for business_031011
Us tmt  social software for business_031011Us tmt  social software for business_031011
Us tmt social software for business_031011
 
2010 internet use_trends
2010 internet use_trends2010 internet use_trends
2010 internet use_trends
 
2010 internet use_analysis
2010 internet use_analysis2010 internet use_analysis
2010 internet use_analysis
 
Pricing healthcare
Pricing healthcarePricing healthcare
Pricing healthcare
 
Dic2000
Dic2000Dic2000
Dic2000
 
Mar2002
Mar2002Mar2002
Mar2002
 
Redes socialesops v230211 Latinoamerica
Redes socialesops v230211 LatinoamericaRedes socialesops v230211 Latinoamerica
Redes socialesops v230211 Latinoamerica
 
Az social media_white_paper
Az social media_white_paperAz social media_white_paper
Az social media_white_paper
 
Informe bernat soria
Informe bernat soriaInforme bernat soria
Informe bernat soria
 
La Sociedad de la Información, Telefónica 2010
La Sociedad de la Información, Telefónica 2010La Sociedad de la Información, Telefónica 2010
La Sociedad de la Información, Telefónica 2010
 
Izo twitter-engage-01-2011
Izo twitter-engage-01-2011Izo twitter-engage-01-2011
Izo twitter-engage-01-2011
 
Leveraging social media for pharmaceutical companies
Leveraging social media for pharmaceutical companiesLeveraging social media for pharmaceutical companies
Leveraging social media for pharmaceutical companies
 
Sanidad pacientes web_2_0
Sanidad pacientes web_2_0Sanidad pacientes web_2_0
Sanidad pacientes web_2_0
 
Ifhp price report2010_comparativepricereport29112010
Ifhp price report2010_comparativepricereport29112010Ifhp price report2010_comparativepricereport29112010
Ifhp price report2010_comparativepricereport29112010
 
Informe Farmaindustria 2009
Informe Farmaindustria 2009Informe Farmaindustria 2009
Informe Farmaindustria 2009
 
informe biocat_2009_es
informe biocat_2009_esinforme biocat_2009_es
informe biocat_2009_es
 
Valoracion financiacion gasto sanitario Fundación BBVA
Valoracion financiacion gasto sanitario Fundación BBVAValoracion financiacion gasto sanitario Fundación BBVA
Valoracion financiacion gasto sanitario Fundación BBVA
 
Informe sectorial 2010 sanidad
Informe sectorial 2010   sanidadInforme sectorial 2010   sanidad
Informe sectorial 2010 sanidad
 

Último

Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls Available
Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls AvailableVip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls Available
Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls AvailableNehru place Escorts
 
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...narwatsonia7
 
Bangalore Call Girls Nelamangala Number 7001035870 Meetin With Bangalore Esc...
Bangalore Call Girls Nelamangala Number 7001035870  Meetin With Bangalore Esc...Bangalore Call Girls Nelamangala Number 7001035870  Meetin With Bangalore Esc...
Bangalore Call Girls Nelamangala Number 7001035870 Meetin With Bangalore Esc...narwatsonia7
 
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...Dipal Arora
 
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Varanasi Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service AvailableDipal Arora
 
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...aartirawatdelhi
 
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service AvailableDipal Arora
 
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...narwatsonia7
 
Lucknow Call girls - 8800925952 - 24x7 service with hotel room
Lucknow Call girls - 8800925952 - 24x7 service with hotel roomLucknow Call girls - 8800925952 - 24x7 service with hotel room
Lucknow Call girls - 8800925952 - 24x7 service with hotel roomdiscovermytutordmt
 
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...Neha Kaur
 
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Nagpur Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service AvailableDipal Arora
 
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...chandars293
 
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...Taniya Sharma
 
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service AvailableDipal Arora
 
Bangalore Call Girls Hebbal Kempapura Number 7001035870 Meetin With Bangalor...
Bangalore Call Girls Hebbal Kempapura Number 7001035870  Meetin With Bangalor...Bangalore Call Girls Hebbal Kempapura Number 7001035870  Meetin With Bangalor...
Bangalore Call Girls Hebbal Kempapura Number 7001035870 Meetin With Bangalor...narwatsonia7
 
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...jageshsingh5554
 
Call Girl Coimbatore Prisha☎️ 8250192130 Independent Escort Service Coimbatore
Call Girl Coimbatore Prisha☎️  8250192130 Independent Escort Service CoimbatoreCall Girl Coimbatore Prisha☎️  8250192130 Independent Escort Service Coimbatore
Call Girl Coimbatore Prisha☎️ 8250192130 Independent Escort Service Coimbatorenarwatsonia7
 
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...hotbabesbook
 
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...Arohi Goyal
 

Último (20)

Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls Available
Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls AvailableVip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls Available
Vip Call Girls Anna Salai Chennai 👉 8250192130 ❣️💯 Top Class Girls Available
 
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...
VIP Call Girls Tirunelveli Aaradhya 8250192130 Independent Escort Service Tir...
 
Bangalore Call Girls Nelamangala Number 7001035870 Meetin With Bangalore Esc...
Bangalore Call Girls Nelamangala Number 7001035870  Meetin With Bangalore Esc...Bangalore Call Girls Nelamangala Number 7001035870  Meetin With Bangalore Esc...
Bangalore Call Girls Nelamangala Number 7001035870 Meetin With Bangalore Esc...
 
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...
Call Girls Bhubaneswar Just Call 9907093804 Top Class Call Girl Service Avail...
 
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Varanasi Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Varanasi Just Call 9907093804 Top Class Call Girl Service Available
 
Russian Call Girls in Delhi Tanvi ➡️ 9711199012 💋📞 Independent Escort Service...
Russian Call Girls in Delhi Tanvi ➡️ 9711199012 💋📞 Independent Escort Service...Russian Call Girls in Delhi Tanvi ➡️ 9711199012 💋📞 Independent Escort Service...
Russian Call Girls in Delhi Tanvi ➡️ 9711199012 💋📞 Independent Escort Service...
 
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...
Night 7k to 12k Navi Mumbai Call Girl Photo 👉 BOOK NOW 9833363713 👈 ♀️ night ...
 
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Coimbatore Just Call 9907093804 Top Class Call Girl Service Available
 
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...
Top Rated Bangalore Call Girls Richmond Circle ⟟ 8250192130 ⟟ Call Me For Gen...
 
Lucknow Call girls - 8800925952 - 24x7 service with hotel room
Lucknow Call girls - 8800925952 - 24x7 service with hotel roomLucknow Call girls - 8800925952 - 24x7 service with hotel room
Lucknow Call girls - 8800925952 - 24x7 service with hotel room
 
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...
VIP Russian Call Girls in Varanasi Samaira 8250192130 Independent Escort Serv...
 
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Nagpur Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Nagpur Just Call 9907093804 Top Class Call Girl Service Available
 
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...
The Most Attractive Hyderabad Call Girls Kothapet 𖠋 6297143586 𖠋 Will You Mis...
 
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...
💎VVIP Kolkata Call Girls Parganas🩱7001035870🩱Independent Girl ( Ac Rooms Avai...
 
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service AvailableCall Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service Available
Call Girls Aurangabad Just Call 9907093804 Top Class Call Girl Service Available
 
Bangalore Call Girls Hebbal Kempapura Number 7001035870 Meetin With Bangalor...
Bangalore Call Girls Hebbal Kempapura Number 7001035870  Meetin With Bangalor...Bangalore Call Girls Hebbal Kempapura Number 7001035870  Meetin With Bangalor...
Bangalore Call Girls Hebbal Kempapura Number 7001035870 Meetin With Bangalor...
 
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...
VIP Service Call Girls Sindhi Colony 📳 7877925207 For 18+ VIP Call Girl At Th...
 
Call Girl Coimbatore Prisha☎️ 8250192130 Independent Escort Service Coimbatore
Call Girl Coimbatore Prisha☎️  8250192130 Independent Escort Service CoimbatoreCall Girl Coimbatore Prisha☎️  8250192130 Independent Escort Service Coimbatore
Call Girl Coimbatore Prisha☎️ 8250192130 Independent Escort Service Coimbatore
 
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...
Night 7k to 12k Chennai City Center Call Girls 👉👉 7427069034⭐⭐ 100% Genuine E...
 
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...
All Time Service Available Call Girls Marine Drive 📳 9820252231 For 18+ VIP C...
 

2010 european trends in aggregate spend, transparency and disclosure

  • 1. 2010 European Trends in Aggregate Spend, Transparency, and Disclo- sure 2010 European Trends in Aggregate Spend, Transparency, and Disclosure November 2010
  • 2. Exclusive Survey Results on Life Sciences Industry Regulatory Compliance Trends... COMPLY
  • 3. e White Paper 3 Life Sciences companies across Europe are facing a series of emerging global legislation and increased regulatory enforcement, designed to prevent corruption and bribery. But how well placed are these organisations to comply with the need for improved information transparency and aggregated healthcare practitioner spend data? And how will the European regulatory climate compare to the more mature U.S. regulatory model? Cegedim Relationship Management has undertaken its first annual survey into pharmaceutical compliance activity across Europe. The objective is to continuously evaluate industry trends and best practices for operational compliance. The 2010 regulatory compliance survey reveals Life Sciences companies across Europe are now very aware that regulatory compliance and compliance management is a challenge – a challenge that will drastically change the way companies behave and they way they interact with healthcare providers and customers. These organisations are also very aware that compliance with new regulations, such as the UK Anti-Bribery Act, will have a significant impact on the industry’s image. Done well, regulatory compliance should have a very positive effect on image. However, if one company fails to step up to the mark and receives high-profile fines, the industry impact will be very detrimental. As a result, organisations across the Life Sciences industry are cooperating and collaborating to determine and define the standards required. These companies are certainly looking at the U.S. regulatory market, with three quarters (75%) of the respondents believing methods of tracking promotional spending currently used in the U.S. will be deployed in Europe. But while European regulators are closely following the more mature U.S. model, the clear cultural differences between Europe and the U.S. will undoubtedly have an impact on the future regulations. In the U.S., organisations must proactively disclose a large amount of information; from violations to every aspect of healthcare practitioner spend, under the Sunshine Act that comes into effect in 2013, specific to 2012 interactions with healthcare practitioners and organizations. This enforcement model reflects the high levels of regulation and enforcement applied across every U.S. industry, from finance to utilities. In Europe, however, there is a far greater emphasis on self-policing. Life Sciences companies are being asked by the authorities to improve information transparency and provide aggregated spend information. But, at the moment, the final concept of transparency – and whether it will be enforced – is still to be determined. However, there is no doubt that the new regulatory requirements, at global, regional and local levels will affect the way Life Sciences companies do business; with 93% of respondents agreeing that regulatory compliance will be a major challenge in Europe. Executive Summary 93% agree that regulatory compliance will be a major challenge in Europe
  • 4. White Paper4 7% 6% 8% 83%Pharmaceutical Company Medical Device Company Biotechnology Company Other, Please Specify There is little doubt that companies in the U.S. are ahead of the regulatory curve – perhaps three to five years ahead of their European counterparts. This market has been highly regulated for several years, and the forthcoming Sunshine Act includes even greater demands for spend transparency. As a result, U.S. Life Sciences companies are heavily focused on operational compliance, working hard on the key issues of improving data quality, meeting regulatory reporting requirements and vendor management. As this data is compiled, many are starting to leverage the insights from this information to share across their organisations to achieve productivity gains. By contrast, in Europe, compliance officers are still determining policy, assessing the implications of global, regional and local regulatory requirements. Indeed, for many companies, the process of creating a regulatory compliance team is still in its infancy. There are lessons that European companies can learn from the U.S. that should streamline the regulatory compliance process and drive down the cost of this essential but non-core activity. Issues of data quality remain a massive problem for U.S. Life Sciences companies, despite the huge investment already made. It is also important to gain business-wide involvement in compliance activity – from senior management commitment, to the IT team that must be involved in executing the regulatory compliance programme and the business people who own the data. Indeed, in the U.S., after several false starts, it has become apparent that the most successful regulatory compliance programmes are owned and driven by business people. Following this model will help European Life Sciences companies reduce time to market and the cost of regulatory compliance. Furthermore, growing numbers of U.S. companies are turning to dedicated third party solutions for support in the compliance activity – with around 44% either already using or planning to take this approach. This survey reveals that European companies are beginning to follow suit, although in much smaller numbers. As the U.S. forges ahead with operational regulatory compliance projects, it has become apparent that managing the volume of regulatory change and reconciling diverse data sources to deliver transparency, is too challenging to handle internally. The use of third party providers is becoming key in adhering to policies and procedures while effectively tracking aggregate spend, identifying suspicious financial transactions and streamlining regulatory compliance monitoring. But there is one area where Europe is already ahead of the game, at a planning level at least, namely, leveraging transparency and aggregate spend information to derive benefits above and beyond compliance. 83% agree the implementation of transparency guidelines will lead to better resource allocation; whilst almost two thirds (62%) agree implementation of transparency guidelines will generate promotional spend decreases. This first annual survey provides a fascinating insight into the nascent regulatory landscape in Europe. It reveals that Life Sciences companies are investing in regulatory compliance and assessing policies and procedures. But it also raises concerns about timing and the need to extend monitoring beyond traditional sales and marketing functions. With demands for information transparency looming, Life Sciences organisations must now move beyond the planning stage, consider every aspect of spend and embark upon operational compliance programmes. Figure 1 - Awareness of Regulatory Compliance Requirements
  • 5. e White Paper 5 Regulatory compliance will grow as a strategic challenge for the Life Sciences industry within the next three years with the growing implementation of new regulatory legislation and compliance requirements: 93% of respondents agree that regulatory compliance will be a major challenge in Europe. Specifically, 82% believe that anti-corruption regulation (Foreign Corrupt Practices Act, UK Anti-Bribery Law) will impact the regulatory environment and global transparency requirements. Almost two thirds (62%) agree that the implementation of transparency guidelines will generate promotional spend decreases. The European compliance function is mostly focused on high-level compliance governance design and validation – as opposed to the U.S., where compliance is being implemented at an operational level, with an emphasis on data, reporting and vendor management The U.S. transparency and aggregate spend model is likely to spread across Europe, leading to an increase in companies’ investments Over half (53%) of respondents anticipate their investment in aggregate spend transparency to grow. Data identification, consistency and quality are the major challenges in project implementation and compliance governance processes 22% of companies in Europe are using Excel today to monitor expenditure. This is set to drop to 10% as organisations increase their dependency on third party solutions to meet compliance requirements. Organisations in Europe are looking to exploit greater information transparency to derive further benefits beyond compliance: 83% agree the implementation of transparency guidelines will lead to better resource allocation Key Findings 6% 73% 22% 5% Somewhat informed Not at all informed Very well informed 40% 38% 49% 36%26% 53% 47% 44% Implementation of transparency guidelines will lead to a better resource allocation. Regulatory compliance will be a major challenge in Europe. Completely Agree Mostly Agree Implementation of transparency guidelines will generate promotional spend decreases. Regulatory compliance environment will have a major impact on the Life Science industry image. Figure 2 - Awareness of Regulatory Compliance Requirements Figure 3 - Regulatory Compliance Outlook
  • 6. White Paper6 Whether or not it was merited, there can be no argument that Life Sciences organisations are now firmly in the spotlight of anti-corruption and anti- bribery officials. Global polices regulating promotional expenditure and sample distributions are being reinforced, whilst in the U.S. Life Sciences companies have experienced both dawn raids and serious investigations by the Department of Justice. And the implications are significant; pharmaceutical and medical device companies can face both civil and criminal sanctions. Siemens was recently fined more than $1 billion for not maintaining accurate books of records, while individual executives from well-established international companies are being prosecuted for not having implemented enough internal control and validation measures. Furthermore, the series of legislation facing Life Sciences companies continues to grow. The recently revisited UK Anti Bribery Act comes into force in April 2011 and adds even more complexity to the existing Foreign Corrupt Practices Act (FCPA), the Organisation for Economic Co-operation and Development (OECD) Convention and the Sunshine Act due to come into force in the U.S. in 2013. But just how geared up are European Life Sciences companies for this new regulatory intensity? In the first annual compliance survey conducted by Cegedim Relationship Management, the results revealed some awareness (95%) of the growing regulatory compliance requirement and the majority (73%) are very well informed. Meanwhile, over eight out of ten respondents (82%) believe the coming anti-corruption regulations, such as the FCPA and UK Anti-Bribery Law will highly (38%) or somewhat (44%) impact the regulatory environment. Less than two out of ten (16%) feel that there will be low or no impact. But understanding the extent of that impact remains a challenge. European Life Sciences companies do not necessarily want to follow the U.S. route which will require companies to publish online all spend to healthcare professionals - both direct and indirect. This highly-enforced regulatory environment does not fit comfortably with the European culture of self-regulation. However, European regulators are currently looking closely at the U.S. model to determine the right route forward and three quarters (75%) of the respondents believe that methods of tracking promotional spending currently used in the U.S. will eventually be deployed across Europe. Approximately one-half (47%) believe that they will probably come; around one-quarter (28%) believe that they are likely to come. And just one in ten (10%) believe that they are not coming. Certainly organisations are aware of the implications of escalating compliance demands. 93% of respondents agreed that regulatory compliance will be a major challenge in Europe; and 93% also say the regulatory Introduction 82% believe the coming corruption regulations will impact the regulatory environment
  • 7. e White Paper 7 compliance environment will have a major impact on the Life Sciences industry image. However, it is apparent that despite well-publicised regulatory compliance recruitment programmes, the responsibility for compliance in Europe still rests primarily with sales and marketing teams. 117 individuals contributed to the research; 83% of these were from pharmaceutical, 8% medical device and 6% biotechnology companies. Just 26% of respondents, however, have a dedicated regulatory compliance role; while 29% are in marketing and 18% in sales. In contrast in the U.S., 32% of respondents were in compliance and 21% in operations; just 14% were in marketing and 13% in sales. However, it is good to note that in the European research, 7% are in general management; 5% in finance/audit; 4% in public/government affairs and 4% in medical, demonstrating the growing realisation that compliance must become a part of the daily business life across every part of the pharmaceutical organisation. The emphasis on sales and marketing personnel taking control of regulatory compliance requirements also reflects the fact that the European marketplace is still focused heavily on tracking sales and marketing spend to healthcare professionals rather than every aspect of spend, such as support for clinical trials which also will demand input from R&D and public affairs. Furthermore, while the majority (88%) of these individuals have a direct involvement in mandate marketing and promotional spend laws, only 51% are very involved in healthcare professionals spend tracking and monitoring process based on existing laws and legislations. In the U.S., by comparison, 69% of respondents were very involved in spend tracking and monitoring. No doubt the level of European involvement will increase as the compliance function in Europe becomes more mature. 29% 26% 18% 7% 5% 4% 4% 3% 2% 2% 10% Marketing Compliance Sales Management (General) Finance/Audit Public/Government Affairs Medical Legal Technical Operations (IS) R&D Other Figure 4 - Report Participant Demographics
  • 8. White Paper8 Understanding Compliance So how confident are these organisations in achieving fast emerging regulatory compliance demands? According to the research, almost three-quarters (73%) of the respondents say that their company is either excellently (31%) or well equipped (42%) to comply with transparency regulations as they exist today. Just one quarter (25%) feels that their company is fairly (22%) or poorly (3%) equipped to deal with transparency regulations. This compares with just 29% of companies in the U.S. believing the organisation is either excellently or well equipped to comply. This clearly reflects the different levels of maturity in the U.S. and the very strong culture of enforcement: in the U.S., organisations have to demonstrate regulatory compliance to what are far more stringent regulations that span the entire organisation, not just the sales and marketing role; whilst in Europe there are, as yet, no best practice guidelines or benchmarks for regulatory compliance activity. Given that far more stringent regulations are expected in Europe shortly, the results suggest a worrying level of complacency amongst organisations. And those that only rate their ability to comply as ‘fair’ today, in what is a relatively unregulated environment, should be particularly concerned about how they will address compliance at global, regional and local levels over the coming 12-18 months. The research also revealed that organisations are still developing strategies to deliver effective transparency projects. Indeed, when asked to describe their role in the company’s involvement with locally-mandated marketing and promotional spend compliance, the majority of respondents (60%) said they were directly involved with process design and implementation. Approximately four out of ten are involved with data analysis (44%) and report review and approval (39%); approximately three out of ten are involved with tracking legislative updates (30%) and gathering and/ or entering of data (25%); while approximately two in ten are involved in report generation (19%), processing data (18%), vendor selection (16%) and vendor management (15%). In contrast, U.S. Life Sciences companies are three to five years ahead with the implementation of operational-based compliance solutions, with a far higher emphasis on areas such as data processing, report generation and vendor selection. It is understandable that these European organisations are focusing attention on understanding the regulatory compliance requirements, particularly since local and regional interpretations of regulations vary. The differences can range from not bribing “public officials” – a term that itself can be interpreted differently across the globe depending on the way health services are delivered; to the new Anti-Bribery Law that includes both private and public Healthcare sectors in the UK. This law also has far tougher sanctions than other legislation: an individual convicted for failing to implement adequate measures now faces up to 10 years in prison and unlimited fines. U.S. Life Sciences companies are three to five years ahead with the implementation of operational-base compliance solutions
  • 9. e White Paper 9 Furthermore, each country has a different limit for the amount of promotional spend allowed per official – for example, small gifts cannot exceed £6 in the UK, but €30 in Spain or 100 zloty in Poland. And even the use of samples is significantly reduced, with organisations now complying with the ‘four times two’ standards – no more than four samples per physician for two years after the product’s launch – laid down by the European Federation of Pharmaceutical Industries and Associations (EFPIA). Despite this complexity, the survey highlighted opportunities associated with compliance activity – most notably the value of creating and providing aggregated spend information to the business as a whole. Some 83% agree the implementation of transparency guidelines will lead to better resource allocation; while almost two thirds (62%) agree implementation of transparency guidelines will generate promotional spend decreases. These figures make it clear that organisations across Europe are already looking to derive benefits beyond compliance from this investment by better understanding the deployment of resources in terms of both people and investment. This contrasts heavily to the U.S. where there has traditionally been a clear line between compliance and the business: organisations in the U.S. are only now beginning to look at attaining possible business benefits from regulatory compliance data. The business-based attitude of the European market should enable companies not only to embed compliance activity in every part of the organisation but also derive additional benefits faster. 3% 22% 42% 31%Excellent Good Fair Poor Figure 5. Ability for Company to Comply with Transparency Regulations Today
  • 10. White Paper10 Given the awareness of the importance of regulatory compliance activity to the Life Sciences industry, just how committed are these organisations to investing in the right people, processes and technologies to drive successful compliance programmes? Over half (53%) of respondents anticipate their investment in solution and resources to provide aggregate spend transparency to grow, reflecting the growing awareness of the compliance risk across both the industry and Europe. And of the 40% that expect investment to stay the same, the majority of respondents are in country-based, rather than regional roles revealing a gap between local and regional compliance understanding. So how will this investment be made? Today over half (56%) are using internal software systems to monitor company expenditure in Europe; and 22% are reliant on manual processes and Excel spreadsheets; with just 10% using a dedicated third party solution. When asked how the company planned to satisfy spend transparency requirements tomorrow, there is a significant shift away from manual processes. Indeed, just 10% plan to use Excel in the future. Instead, 56% will use internal software systems; and 19% will use third party solutions. Given the comparative sophistication of the U.S. marketplace, it is interesting to see how attitudes to monitoring aggregate spend compare. Today in the U.S., some 40% are still reliant on Excel, 32% use internal software systems, 24% third party solutions and 4% do not monitor at all. In the future, the majority (44%) plan to adopt dedicated third party software; 31% will use internal software systems, while 17% plan to remain with Excel. Certainly this shift away from manual processes is critical. The new regulatory implications extend far beyond traditional detailing activity and embrace every part of the organisation that has any kind of customer interaction, from engaging with customers in clinical trials, to providing grants to physicians or simply inviting a Key Opinion Leader to a progress meeting. Also companies will have to include all payments made on their behalf by external partners and third parties companies. Therefore, pharmaceutical companies now need to track every interaction and financial transaction, monitor both direct and indirect payments undertaken on behalf of the organisation, and then reconcile the expenses to each physician or official. This process becomes even more complex when considering the multi-national nature of most Life Achieving Compliance Figure 6. Anticipation of Level of Investment on Aggregate Spend Level for Next Year 3% 11% 40% 42%Increase Stay the same Significant increase Decrease 83% Agree the implementation of transparency guidelines will lead to better resource allocation
  • 11. e White Paper 11 Sciences company operations: organisations have to put in place global guidelines and consistent standards to monitor closely all interactions with healthcare professionals. They have to be able to reflect the different regulations in each country; and they need to achieve this without incurring an unmanageable, expensive overhead. This huge shift towards third party software, especially in the U.S., is a clear indication of the need for support in designing and implementing robust processes for creating aggregated spend data that encompasses more than just sales and marketing expenditures. In Europe, Customer Relationship Management (CRM) provides companies with an easy route to collate the sales and marketing aspect of spend information. The significant numbers of organisations looking to adopt third party solutions in the U.S. demonstrates recognition that when organisations have to include information from R&D, medical affairs and third party vendors, there is a need for external support in areas such as data management and aggregation. As the compliance model in Europe becomes more mature, it is very likely the same patterns of third party software adoption will be followed. And a fundamental component of this process is the creation of a unique customer record – a problem that has been extremely understated, even in the mature U.S. market. Pulling information from multiple, diverse systems - from ERP to third party vendors - and ensuring spend is reconciled to a single, accurately identified customer, is a significant challenge. Customer data will be often incomplete and recorded differently in each system. How can an organisation ensure that Dr. Brown is the same Dr. Patrick Brown, or hospital consultant Pat Brown in Manchester? U.S. companies are investing heavily in creating excellent customer Master Data Management (MDM) systems, the core component of the transparency process. Yet just 15% of U.S. companies are very confident in the ability of the internal customer MDM system to define the unique recipient records across all spend sources; with 31% somewhat confident. In Europe, by contrast, where organisations have yet to embark upon the creation of MDM, one quarter (25%) of respondents are very confident in the ability of internal systems to define the unique recipient record across spend sources or across countries; while 37% are only somewhat confident. Again, this difference reflects the sales and marketing emphasis of the European compliance activity to date, with companies reliant upon and confident in the quality of their CRM systems. However, true transparency will require cross-system information provision and failure to define the unique recipient (customer) record across all spend sources or across countries will lead to the failure of the entire compliance project. Figure 7. Functions to Ensure Compliance with Local Mandated Marketing and Promotional Spend Regulation 60% 44% 39% 30% 25% 19% 18% 16% 15% 13% Process design and implementation Data Analysis Report review and approval Tracking legislative updates Gathering and/or entry of data Report generation Processing data Vendor selection Vendor management Other, please specify
  • 12. White Paper12 Data Challenge This issue is reflected in the concerns raised in response to complying with FCPA and regulations such as the OECD convention and UK Anti-Bribery. The greatest concern is collecting all relevant spend data (39%), followed by data integrity (36%) and identification of spend recipients (36%) and preparing reports for data disclosure (34%). Given that Life Sciences companies in Europe will have to report accurately on this data within the next 12-18 months notably in the U.S. and UK, it is clear that organisations must focus hard up- front on enhancing data management governance before embarking upon any further regulatory compliance activity. However, when asked ‘what are the key issues that impact the level of regulatory compliance,’ organisations cited lack of understanding of policy (62%) as the primary impact. Lack of policy knowledge leads to errors in data, therefore organisations need to embark upon company-wide education and training programmes to reinforce the importance of compliance and FCPA to the pharmaceutical business – and the market as a whole. It is no surprise that poor record keeping or data entry errors is the next most significant impact (54%), given the need for high quality data to achieve compliance; if individuals do not understand the policies and procedures, or recognise the need for ethical behaviour, poor record keeping and data errors will be inevitable. Improving education should, by default, lead to better information. The third most important impact is system process shortcomings (52%).  But as the need for a unified, strategic global compliance strategy and view becomes more important, the shortcomings of existing systems for monitoring and reporting aggregate spend will become even more evident. The way in which information is captured is just half the problem.  In the U.S. just 37% of respondents indicate that their company enforces corporate standards for healthcare professional and spend data capture which applies to all suppliers and staff. The remaining respondents either do not have standards or have standards which are not used universally. In Europe, however, where the market is significantly less regulated, some 83% of organisations enforce corporate standards for healthcare professionals and Figure 8. Areas of Concern Complying with the FCPA and Anti-Corruption Regulations 36% 39% 36% 34% 30%Handling inquiries after spend is posted Prepare reports and analysis for potential data disclosure Proper identification of spend recipients Data Integrity - having accurate, certified, complete, and timely data Collecting all relevant spend data
  • 13. e White Paper 13 spend data capture. The majority (62%) have standards that apply to all external parties and internal data; whilst only 21% have standards that only apply to some external parties and internal data. Just 7% of organisations currently have no standards and are not in the process of defining any. Where enforced, these standards apply to honorarium fees (71%); promotional spend (75%) and consultancy fees (68%). Third party data (38%) is less commonly covered. These figures are very revealing. The strong emphasis on sales and marketing related spend underlines the relative immaturity of the European market when compared to the U.S. – and reflects the very different enforcement models applied in these markets.  The challenges associated with collecting and collating this data reflect the problems already encountered in the U.S.; issues include managing disparate formats and standards (37% challenging) and establishing unique identification of healthcare professional from all the expense data sources (35% challenging), identifying all data sources (32%) and managing incomplete spend information (31%).   The implications of these problems are significant. A lack of consolidated customer view created by the inability to uniquely identify a healthcare professional from diverse expense data sources will lead to inaccurate monitoring and reporting, and a risk of compliance breach. But with multiple source systems and owners, file format differences and numerous third party sources, even identifying all the sources before creating the unique customer number is a massive challenge. Add in global regulatory compliance needs and the complexity increases significantly Figure 9. Does your Company Enforce Corporate Standards for Healthcare Professionals and Spend Data Capture Figure 10. How Challenging are the Following Processes? 3% 7% 21% 62%Yes, applies to all the external and internal data Yes, but applies only to external partners and internal systems No, we do not have standards No, but we are in the process of defining one 0% No, looking for a vendor to provide a solution 31% 32% 35% 37%Managing disparate formats and standards Matching and establishing unique identification of a Healtcare Professional from all the expense data sources Identifying all data sources Managing incomplete spend and customer information
  • 14. White Paper14 Robust Model If organisations are to achieve a consistent, global model for regulatory compliance, it is essential to create a standard data capture model that also supports local rules to ensure every market is managed consistently and effectively. As a dire imperative, organisations need to consider not only spend aggregation but also robust and thorough customer data management. One option is to put in place an aggregate spend solution that builds on existing Key Account Management (KAM) information to automate and streamline regulatory compliance monitoring and reporting. It is by leveraging this strong, accurate data source and integrating a wide range of enterprise applications for Sales Force Automation, ERP, Finance and HR, that organisations can streamline and automate the process of highlighting suspicious transactions. Using Business Intelligence, Life Sciences companies can not only conduct the required in-depth historic analysis but also put in place proactive alerts both for individuals identified as highly influential and also if payments to specific practitioners are about to hit the threshold (Fair Market Value); preventing both intentional and accidental compliance breaches. There is a further component to compliance activity, namely transparency. In this global operating environment organisations are increasingly looking at opportunities to drive best practice, create global policies with local implementation and improve processes and key to this is to improve transparency. This regulatory compliance drive is now enabling organisations to collect and share information not only with government and regulators but also internally. Indeed, the wealth of financial information collected to achieve compliance provides valuable insight into cross-organisational spend with specific healthcare providers. Adding customer data management to the process provides a depth of information that can be analysed to assess value, understand how much is being spent at an individual level and improve resource allocation. This improved insight also has implications for Key Account Managers. The aggregate spend information can be analysed to provide a Key Account Manager with insight into spend at a local level, such as investment in training or continuous medical education (CME) to a physician. With a complete picture of the investment by organisation, a Key Account Manager embarking upon negotiation for a new bid or new customer is in a far stronger position to demonstrate the value being provided by the Life Sciences company. This is a powerful tool that, if used correctly, should have a direct, bottom line impact on business. Using Business Intelligence, companies… can put in place pro-active alerts. Preventing both intentional and accidental compliance breaches
  • 15. e White Paper 15 Conclusion Transforming the image of the Life Sciences industry will take time. But the commitment being demonstrated today is extremely positive. And whilst organisations are obviously keen to avoid the negative publicity, fines and possible court cases associated with bribery and corruption, there is no doubt that organisations in Europe are also looking to derive benefits from improved transparency, whether for internal compliance reasons or external disclosure. With a real opportunity for a Life Sciences company to establish a good image to the healthcare market, the industry is increasingly considering transparency as a huge competitive advantage and benefit, and an opportunity to improve resource utilisation, rather than simply an expensive and time-consuming overhead expense. But, while the commitment is not in doubt, organisations are still struggling to actually deliver transparency, both from a technology and business model perspective. This is a multi-disciplinary project that is not just about exploiting technology but also about driving new behaviour change and imposing compliance as a change in ethical behaviour to the customer. Critically, global regulatory compliance and transparency demands an automated and streamlined solution: not only are the costs of a manual or spreadsheet approach too high, but without some kind of automation and built-in alerts that reflect the different countries’ interpretations, organisations will be exposed to a high risk of compliance breach. Regulatory compliance is becoming a key function within the Life Sciences business; indeed it is, in some companies, becoming a cornerstone of how business is conducted and is massively influencing the commercial model. But for the industry to achieve wholesale changes in attitude and perception, every organisation needs to commit. Without that, European Life Sciences companies will face the highly enforced model being adopted in the U.S., rather than a self- policing approach – a model that many fear will significantly undermine customer relationships. Now is the time to work with other organisations in the field to develop best practices, to assess how to best leverage existing spend capture sources and resources, and to put in place procedures and practices that will mitigate both the risk and cost associated with global compliance. Authored by; Bill Buzzeo VP and GM of Global Compliance Solutions Cegedim Relationship Management william.buzzeo@cegedim.com Guillaume Roussel VP Compliance Solutions EMEA Cegedim Relationship Management guillaume.roussel@cegedim.com Exclusive Survey Results on Life Sciences Industry Regulatory Compliance Trends... COMPLY Reproduction and distribution of this report is allowed only with the written authorisation from Cegedim.
  • 16. White Paper16 2010 European Trends in Aggregate Spend, Transparency, and Disclosure For more information, please contact compliance@cegedim.com www.cegedim.com/eucompliance 2010 Cegedim, Inc. All Rights Reserved Reproduction and distribution of this report is allowed only with the written authorisation from Cegedim.White Paper16 2010 European Trends in Aggregate Spend, Transparency, and Disclosure For more information, please contact compliance@cegedim.com www.cegedim.com/eucompliance 2010 Cegedim, Inc. All Rights Reserved Reproduction and distribution of this report is allowed only with the written authorisation from Cegedim.