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Published byCamila Amey
Modified over 2 years ago
CTE / Companion Upgrade Office of Ethics and Compliance December 21, 2011
Sunshine Act review The Sunshine Act will require Abbott to track and report substantially all payments and transfers of value, such as meals, provided to “physicians” and “teaching hospitals” (definitions pending regulations) –All 50 states, D.C. and Puerto Rico –Includes consulting fees, meals, snacks, clinical trials, research, royalties, etc. –The reports Abbott provides will be posted on a public website In preparation for the Sunshine Act, CTE is being modified to collect additional data that will be required for federal reporting The start of the tracking period has not been established but is likely to be in 2012 There is minimal preemption of state requirements CTE / Companion Upgrade2Company Confidential © 2011 Abbott
Companion The January 2011 CTE communication included the information below –Corporate OEC is building a companion tool to CTE Purpose is to capture more detailed data required by the law that cannot be effectively captured in CTE, such as: –More details about the purpose of meals, such as consulting and customer visits –Recipient information for expenses, such as badge fees –Make it easier to select product through division-specific drop-down product lists –Go-live anticipated 4th Quarter 2011 In May, Concur was selected to build the Companion tool as part of CTE based on the following criteria –Evaluate feedback and user experience to make improvements –Minimize training requirements and impact to the users –Maximize flexibility for extended data –Provide additional detailed data for mapping to Spend Purpose Codes –Provide additional detail for monitoring –Leverage CTE core attendee function while simplifying the process for HCP search and request CTE / Companion Upgrade3Company Confidential © 2011 Abbott
CTE expense types Changes to current expense types –Business meals with HCP(s) changed to Food with HCP(s) –Receptions with HCP(s) will require attendees –Airfare for HCP will require a destination City and State Deleted expense types –Snacks with HCP(s) no longer exists Snacks will be a purpose under Food with HCP(s) and will require attendees to be listed New expense types –Ground Transportation for HCP will require collection of information for ground transportation such as Limo, Taxi, etc. and will require an Attendee and a destination City and State –NutraLink was removed from Snacks and will be a new expense type for reimbursement of expenses incurred when buying ANPD food products NutraLink distribution at the HCP level is being evaluated by corporate OEC and divisions –Distribution cannot be built in CTE due to technical limitations –Distribution must be at the retail value –Some divisions may elect to stop distributing product –Some divisions may elect to include tracking in their SFA tools –Reconciliation of quantity ordered with quantity distributed may be desirable CTE / Companion Upgrade4Company Confidential © 2011 Abbott
Additional data requirements New fields in some HCP expense types –Venue For expenses that involve food, Off-site or On-site must be selected –Sub Purpose 1 and Sub Purpose 2 Required when additional information is needed such as an expense related to consulting –National Clinical Trial number (NCT#) Required when a value transfer is related to consulting for a clinical trial –Product will be a required field Product selection cannot be made division specific, however the “type ahead” feature allows users to quickly find the product by typing a few characters of the product name and the “most recently used” feature will show the last ten products selected –Destination city and state Required on “Airfare for HCP” and “Ground Transportation for HCP” expense types –Mode of Transportation Required on “Ground Transportation for HCP” expense type CTE / Companion Upgrade5Company Confidential © 2011 Abbott
Changes regarding HCP attendees/recipients HCP Search –Removed the need to search Licensed and Non-Licensed HCPs separately Licensed and Non-Licensed master files merged into one HCP master file –Simplified search fields Last name, First Name, State and External-ID Changes to HCP Lookup Request –New process to create an HCP Lookup Request After information is entered into the form, Companion will determine if the HCP can be added immediately to the expense report or if an HCP Lookup Request needs to be created and sent to the OEC back office for processing Changes to attendee data –Business name must be entered if it is blank or reads “No Business Name Known” –New field, Primary Employment Type, must be selected if it is blank This field will be blank the first time attendees are selected after the CTE upgrade goes live Field should be evaluated each time an attendee is added to confirm accuracy –The 28 Abbott titles have been reduced to the 18 HMS titles (practitioner types) Simplifies data transfer in preparation for federal reporting CTE / Companion Upgrade6Company Confidential © 2011 Abbott
New functionality Adjustable distribution of amount allocated to attendees –All attendees present must always be added –The total expense is automatically distributed evenly among the attendees –In cases where an attendee does not consume a meal, the amount may be adjusted to zero, the remaining amount will be evenly distributed to the other attendees Entry of deposit or prepayment (ACR / PO) amounts that should not be reimbursed but need to be allocated to attendees –Deposits or prepayments that may have been made in the form of an ACR or PO can be entered into this field and the amount will be automatically distributed to the attendees when records are created for the transparency reporting system CTE / Companion Upgrade7Company Confidential © 2011 Abbott
Key points Always search for your HCP before requesting an HCP Lookup –The master file has over 5 million HCPs and office staff Include all attendees in the expense report –Even if an attendee does not consume a meal, add him or her to the expense report and adjust the amount to zero Add attendees from your Favorites list or the Search results list before clicking the Verify HCP(s) / Request HCP Lookup field When requesting an HCP Lookup, complete the form with as accurate information as possible CTE / Companion Upgrade8Company Confidential © 2011 Abbott
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