compliance review 12 67% risk management 0 0% KOL assessment 0 0% identifying outliers and determining cause 6 33% by top HCP 2 11%

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1 Page 1 of 7 Transparency West Current run (last updated May 25, :41am) Polls Participants Average responses Average engagement How are companies analyzing and/or auditing data? compliance review 12 67% risk management 0 0% KOL assessment 0 0% identifying outliers and determining cause 6 33% How are companies using data to report to Exec Team and/or Board? by top HCP 2 11% by top business unit 0 0% benchmark with industry 5 28% other 11 61% Do companies have consulting payment spend cap? Yes 15 83% No 3 17% If the answer is yes, how do you monitor? A A A % 3

2 Page 2 of 7 Do companies conduct FMV per HCP Yes 16 89% No 2 11% If yes, do you have any outliers? Yes 0 0% No 0 0% 0% 0 How do you handle errors and omissions? Count Percentage use a predetermined threshold to determine if data will change 2 10% correct/add data for present and all past years reports 90% 87% 20 How are you currently handling remediation? 100% remediation and check of all data 9 60% sample check to find out if things are on the right track 4 27% ogic check (ie. speaker event and see speaker fee but no travel attached) 2 % 65% 15

3 Page 3 of 7 What is the biggest challenge with management of global compliance? Culture rules currency Centralization Culture 21 Consistency Cross border Country rules Accurate data Resistance Process alignment Lack of communication Know all the rules for each country Resistance to centralization Buy in Data Collection Budget Buy-in with US perspective Does your organization compare open payments data with other sources of data in the organization? Yes 72% No 5 28% Do you have an established process for auditing/evaluating third parties? Yes 7 37% No 12 63% 83% 19

4 Page 4 of 7 Is your organization using Open Payments data analytics to target your compliance monitoring initiatives? Yes 7 39% No 11 61% When you receive HCP/HCO disputes, do you: contact the HCP/HCO directly with information related to the transactions being disputed? provide the information back to CMS and wait for the disputes to be withdrawn? 15 83% 2 11% Other 1 6% Are you currently reporting study drugs? ex: FDA approved marketed drugs provided by the Pharma manufacturers for Investigator or Collaborative studies Yes 11 73% No 4 27% 65% 15 How are the study drugs reported and what is the method of value associated with the study drugs? Each 4% 1 Response

5 Page 5 of 7 What type of hurdles or roadblocks does the Pharma manufacturers encounter with OUS HCPs/HCOs reporting for US transparency? Lack of information Finding License # Finding them Getting data from affiliates Finding them 22% 5 What type of hurdles or roadblocks does the Pharma manufacturers encounter with OUS HCPs/HCOs reporting for EFPIA and the OUS affiliates? 0% 0 How do you manage attendee capture for reporting? a. We only require the capture of reportable HCPs 3 25% 52% b. We require all attendees (reportable and nonreportable) be captured individually 5 42% c. We have separate processes to manage reportables 4 33% vs. non-reportable but both attendee types are addressed d. Other 0 0% 12 What platform are your sign in sheets on? a. We do not require the use of sign in sheets 1 7% b. We use paper sign in sheets 12 86% c. We use electronic sign in sheets 1 7% 61% 14

6 Page 6 of 7 What process or system do you utilize to capture speaker program details? Count Percentage a. Excel spreadsheet 2 % b. Direct data integration with an agg spend system 3 27% c. File transfer requiring internal business logic formatting 4 36% d. Other 2 % 48% 11 How do you manage late payments discovered after the March 31 deadline? a. We do not report any payments for a previous year once data has been attested b. We include them in the next year s submission period 0 0% 11 85% c. Other 2 15% How do you manage spend adjustments when spend errors are identified? a. We do not make changes to data 0 0% b. We make changes on the report only 4 29% c. We make changes on the report and source data 10 71% 61% 14 How do you manage the reporting of study payments? a. We hire the CRO or vendor to collect and provide a report of reportable spend 2 15% b. We manage them internally 5 38% c. Other 6 46% For events (such as advisory boards, speaker programs) what date of payment do you report? Date the check was cut 6 40% Date of event 9 60% 65% 15

7 Page 7 of 7 How are companies reporting research payments to institutions that are under the same corporate umbrella as THs? Tons Under the TH Tin provided Report against org on TH Follow tin Based on TIN TIN # 52% 12 TIN TIN Direct payment to TH Report to the TH They are not. Based on TIN Do you have a dedicated system process to fix spend errors? a. Yes we have a feature in our system that allows us to process and track any adjustments to spend 4 31% b. No 2 15% c. Yes we fix and track this manually 7 54%