Trends in Aggregate Spend and Disclosure Reporting and Compliance 2011 *Preliminary Results

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1 Trends in Aggregate Spend and Disclosure Reporting and Compliance 2011 *Preliminary Results Preliminary Results 2 nd Annual Industry-wide Survey March 2011

2 Agenda Overview Reporting Practices and Investment Data Identification and Handling Physician Payments Sunshine Provision Global Considerations Confidence in Compliance This document should not be distributed without Cegedim authorization Copyright

3 Increase in Aggregate Spend and Disclosure Laws Transparency is becoming the rule Many states and federal government have enacted legislation regarding disclosure of promotional spend Each law has different required information and report format State and Federal Disclosure of Samples New federal law adds layer of complexity Companies will be scrutinized more Spending information will now be available to public on the web As a result, Life Sciences companies are required to track and report on more detailed information than ever before. This document should not be distributed without Cegedim authorization Copyright

4 Other Considerations Global transparency trends PhRMA Code on Interactions with HCPs AdvaMed Code of Ethics Anti Bribery regulations (i.e., US Foreign Corrupt Practices Act, UK Bribery Act) OECD Convention (36 countries) International anti-corruption instrument focused on the supply side of the bribery transaction This document should not be distributed without Cegedim authorization Copyright

5 Goals of the Survey Cegedim surveyed the industry to identify current practices and expected trends around aggregate spend and disclosure reporting and compliance. Comparison to 2010 Results 5

6 OVERVIEW This document should not be distributed without Cegedim authorization Copyright

7 Overview of Respondents 60 respondents from Pharma/Biotech/MedDevice Companies involved in ensuring their company complies with state and federal mandated aggregate spend and disclosure requirements 7

8 Departments in which respondents work Respondents work across a number of departments with compliance making up over a third. 8

9 Company size 9

10 REPORTING PRACTICES AND INVESTMENT This document should not be distributed without Cegedim authorization Copyright

11 How respondents currently satisfy aggregate spend and disclosure requirements While lower than in 2010, almost a third of respondents still report using spreadsheets to comply in 2011 Some respondents indicated either not satisfying requirements or avoiding promotional spend where disclosure is required 11

12 Expected plan to satisfy requirements as more laws are implemented Most people expect to comply with either an internal or third party solution as more requirements are implemented While over 30% of respondents currently report manually or with spreadsheets, less than 10% say that will continue as more laws are enacted 12

13 Costs incurred from third party system implementation Close to have half of respondents have spent between $500K and $1M on third party system implementation for aggregate spend and disclosure reporting *New question for

14 Employee support for aggregate spend and disclosure compliance While the majority of respondents have 1-5 dedicated full time employees (FTEs) to support aggregate spend and disclosure compliance, there was a large increase in the number of people who reported having 6-10 FTE s indicating an increase in investment from

15 Investment in aggregate spend and disclosure compliance The majority of people expect investment in aggregate spend and disclosure compliance to increase over the next year even more so than in 2010 The most notable reason for the expected increase and investment was dealing with more requirements, including the Physician Payments Sunshine Provision 15

16 Managing resources Based on resources, how do respondents currently manage their aggregate spend and disclosure compliance solution vs how they would prefer to? How currently manage solution How would prefer to manage solution *New question for

17 DATA IDENTIFICATION AND HANDLING This document should not be distributed without Cegedim authorization Copyright

18 Data Identification Compared to 2010, respondents are progressing in the process of establishing which data sources and data locations will be used in their aggregate spend and disclosure reporting 18

19 Customer master within aggregate spend solution More companies are realizing the importance of having a customer master with only 10% reporting that they don t have one, compared to 17% in A third of respondents have built a custom customer master solution within their aggregate spend and disclosure solution, up from 23% last year. 19

20 Associating HCPs to a state Similar to 2010, a combination of Address and SLN is the most popular method to associate a Health Care Practitioner (HCP) to a state for reporting 20

21 Reporting of US physicians that travel abroad on your behalf When traveling abroad on their behalf, most respondents pay physicians in the US and in US dollars *New question for

22 Obtaining event and spend data from vendors About a third of respondents still obtain vendor spend data solely from spreadsheets However, there is a significant increase of respondents using a combination of methods indicating that companies are becoming more flexible. 22

23 Number of HCP data sources Overall, respondents report having more data sources related to capture HCP and Organization spend with 41% indicating having more than 10 in 2011 versus only 27% in

24 Challenges in consolidating spend data from multiple sources Significant challenges remain with establishing unique Identification of an HCP and Organizations and with disparate data formats and standards 24

25 PHYSICIAN PAYMENTS SUNSHINE PROVISION This document should not be distributed without Cegedim authorization Copyright

26 Physician Payments Sunshine Provision More people are aware of the Physician Payments Sunshine Provision than last year? 26

27 Level of concern with the Physician Payments Sunshine Provision Respondents level of concern with the Physician Payments Sunshine Provision is about the same as last year 27

28 Moving from a manual solution in response to the Physician Payments Sunshine Provision 77% of respondents who currently use a manual solution to satisfy aggregate spend and disclosure requirements plan to move to an automated solution in response to the federal law (up from 64% in 2010) 28

29 GLOBAL CONSIDERATIONS This document should not be distributed without Cegedim authorization Copyright

30 Importance of implementing a global solution Over a third of respondents indicate that it s a necessity to implement an aggregate spend and transparency solution that can be used in other countries across the world *New question for

31 Geographical priorities in a global solution Europe and Asia Pacific are reported as priorities in respondents consideration of implementing a global aggregate spend and transparency solution (Please check all the apply.) *New question for

32 Decisions on global aggregate spend and transparency initiatives Over half of respondents indicate that global aggregate spend and transparency initiatives originate in US offices, while 25% originate from local or regional offices *New question for

33 FCPA responsibilities Only a third of respondents indicate having some responsibility for their company's compliance with FCPA (Foreign Corrupt Practices Act) *New question for

34 UK bribery law About half of respondents indicate that the UK bribery law will change how they comply with current anti-bribery laws (i.e. FCPA) *New question for

35 Timeframe for implementing a global aggregate spend and transparency solution The majority of respondents have not defined when they will move forward with a global solution for aggregate spend and transparency reporting *New question for

36 CONFIDENCE IN COMPLIANCE This document should not be distributed without Cegedim authorization Copyright

37 Confidence in customer master to define recipient records across all data sources Overall, respondents are only slightly more confident in the ability of their internal customer master management system to define the unique recipient records across all spend sources 37

38 Confidence in reporting process to collect all reportable recipient spend data Respondents confidence in the ability of their reporting process to collect all spend data for recipients that are defined as reportable has increased over the past year Confidence 38

39 Overall confidence in compliance Respondents are slightly more confident that their company is compliant with current disclosure requirements 39

40 Causes of lack of compliance to promotional spend regulations System/process shortcomings and poor record keeping and/or data entry continue to be the top causes of compliance issues 40

41 Survey is open until March 18 th. Thank you This document should not be distributed without Cegedim authorization Copyright