Improve Compliance Effectiveness

Attest Open Payments™ provide two perspectives to improve the effectiveness of the corporate compliance program: "retrospective" focusing on previously publically disclosed data and "prospective" working with internal or pre-disclosed data:

Improve Insight

Retrospective Analysis (e.g., 2013, 2014, 2015 data)

Attest™'s retrospective analysis is comprised of all U.S. physician related payments and other transfers of value. Using a census of payments provides the most comprehensive way to interpret and understand your own payment policies and practices in the context of other comparable organizations and brands. Attest™ retrospective analysis rapidly identifies potential kickback, off-label promotion, conflicts of interest and errors in reporting. From these insights you are empowered to make targeted changes to your policies and organizational practices to improve overall compliance effectiveness. In other words, Attest™ retrospective analysis of U.S. physician and healthcare financial relationships illuminates your greatest areas of compliance risk.

Prospective Analysis (e.g., 2016 data)

Attest™'s prospective analysis is "smart monitoring" and consists of the same comprehensive examination as the retrospective analysis. However prospective analysis can be employed:

  • "early alert" to your organization's internal monitoring and audit program,
  • verify your policy practices,
  • independently test the correctness of your "transparency" data PRIOR to federal, state and or CIA reporting, and
  • intercompany benchmark your compliance policies and practices.

Attest™ is flexible and can provide the organization preemptive assessment on a monthly, quarterly, biannually or ad-hoc basis. Benefits include same as the Retrospective Analysis PLUS mitigating False Claims Act, Anti-Kickback Statute and Stark Law liabilities by enabling you to be timelier in self-identifying discrepancies and demonstrating "reasonable inquiry".

Frequently Asked Questions

  • What are my compliance policies pertaining to U.S. HCP/HCO payments?
  • What are my actual practices versus my intended practices; as it pertains to my established policies?
  • How do I objectively benchmark & defend my policies?
  • How can I be more efficient & effective in how I internally monitor & audit my practices?
  • How do I independently verify the accuracy of my compliance programs?
  • How do I detect reporting & policy practice errors earlier or just be more proactive?
  • How do I continually improve my compliance (i.e., effectiveness)?
  • How can I detect off-label promotion spend?
  • How can I detect outlying payment spend to physicians?

Blog Articles

Caveat User, Caveat Emptor - Issues from the Soft Under Belly of The CMS Data Sets
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Detecting the "Sham" in Speaker Programs
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“Open Payments – A New Source of Clinical Site Intelligence”
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Workshop Speaker, "Demonstrating Compliance to the Department of Justice"
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Coauthor, “Are Phase 3 Clinical Trials Really Becoming More Complex?”
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