Real Stories. Real World.

To Report or Not to Report – A Process Hiccup Uncovers an Important Learning Opportunity

…The great sculptor and painter Michaelango once wrote “ancora imparo,” which means “still I am learning,” as an inscription on a sketch. He was 87 at the time.

At S3 Comply, we’re big believers in a Growth Mindset, especially when it comes to our own “art” of aggregate spend compliance. The industry and regulations are continually evolving, so we’re always learning to stay on top of our game – for our clients and quite simply, because we enjoy it! Even the challenges of the pandemic have offered unique opportunities to learn, partner, and grow at every turn – from new ways to connect with each other and our clients, to new ways to solve problems together and deliver the highest quality aggregate spend data.

We also take pride in our ability to help our clients in this ongoing learning process. Let’s face it…aggregate spend data can be pretty overwhelming in its complexity and its sheer volume. So, in addition to helping our clients bring order to the chaos, we enjoy supporting our clients in better understanding the process. We frequently share tips, resources, and guidance – which not only minimizes stress for our clients, but also helps our clients provide the S3 Comply team with better “ingredients” for our process – reducing bumps along the road.

Here’s a recent example that highlights the importance of a shared commitment to learning – and open lines of communication…

The Background

Our team performs a periodic review of time and expense data for one Pharma client, including a review of the modest meals or small group events hosted by company representatives. We focused on those with reported HCP’s and “business guests.” Our job was to confirm their identifies and demographics – and ultimately to assess reportability.

As an international company, this Pharma client has operations in several countries, including Canada and the US. Since HCP/HCO reporting is voluntary in Canada, our client originally chose NOT to report members of the Canadian team who were identified as “business guests,” because they assumed they were not reportable.

A deeper dive into the names and backgrounds of these individuals by the S3 Comply “detectives” uncovered that one “business guest” of the Canadian company team was an internationally-known medical doctor who resides in the U.S. and is affiliated with a U.S. University. We also discovered that this person has an NPI number! Therefore, the In Kind transfer of value IS reportable under U.S regulation.

The Learning

After all of the data was sorted out properly, we had a great discussion with our client’s Canadian team.

“We explained that it’s always easier to err on the side of assuming ALL possible business guests are reportable – instead of having to go back to uncover items that were missed,” said Sandy Kinsey, Chief Executive Officer. “Different states have different rules, and those regulations are always changing.”

And this advice really applies to many of our clients. Given the flux of regulations and the variations across countries and US states, we recommend assuming a piece of data is reportable if there isn’t full clarity.

Back to our story…our client appreciated the guidance, and this type of open communication allows us to keep the relationship strong and our shared “roads” as bump-free as possible.

And to circle back to where we started, the S3 Comply team is always open to any learning on our end as well. In particular, we are eager to hear suggestions as to how we can serve our clients better – so we encourage you to reach out if you have any feedback or suggestions.

Ancora imparo! Still we are learning. Together as an S3 Compy team – and together with our clients. Thank you for being our partners on this journey!


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