The Expansion Of Pharmaceutical Sales Rep State Reporting and the Challenges It Poses
Within the last few years there has been an uptick is Sales-rep based transparency reporting within the United States. Standard state reporting has shifted focus to Pharmaceutical Sales and Marketing representatives and their interactions with HCPs and their staff.
Nevada led the pack with this type of report in 2017 with Oregon in 2021 and Connecticut in 2023 following suit. Although these reports are similar in nature, the specifics in terms of fields and requirements differ. This has led to an extra layer of difficulty in gathering the data, determining what is in scope and what pieces of information are needed.
Sales Rep Focused Reporting vs HCP/HCO Focused Spend Reporting
There are two main differentiations between the Sales Rep-focused reports, and more purely Spend focused transparency reports, such as those for Vermont and Massachusetts. Firstly, is the joint fulcrum of both the Sales rep and the HCP recipient, instead of focusing solely on the recipient of the Spend. The second differentiating factor is the expansion of the recipient pool to include HCP Staff. Typical transparency reporting for Pharmaceutical companies is related to just the HCPs; Doctors, Nurses, Pharmacists, etc. These Sales rep transparency reports also want interactions with the staff of the HCPs; Technicians, Receptionists, Medical Assistants, etc. This has added a layer of complexity in regard to collecting this data. Sales reps are now responsible for recording these interactions and making sure to include all participants. For example, if a pharma rep were to cater for lunch at a doctor’s office in NV, they would need to report on all staff that took part in the meal. In some cases, there may be a large number of participants which make proper data collection more difficult to achieve. Sign-in sheets have become much more important as this may be the only reference to who was present.
The reports required by Oregon and Connecticut differ even more in the type of data to be submitted. The previous typical state report focusses on expenses related to HCP’s where a transfer of value takes place. The newer, sales rep transparency reports instead look at all interactions, regardless of monetary involvement, which can include interaction types like phone calls, emails, leave behinds, etc. This non-monetary, interaction type of information usually lives within a CRM system where the rep reports all communication with HCPs. Along with the type of interaction, the location and length may also be required to report. This has forced pharmaceutical companies to enhance the amount of data recorded by and collected from their sales reps.
Sample reporting is another layer added onto these reports. Pharmaceutical companies who give out samples, materials, or gifts to these HCPs are required to report info about them. For example, Oregon wants to know the amount and market value of any items provided. Connecticut wants even more information about samples, specifically for Drugs including their Name, Strength, Dosage, and more.
As a result of these Sales rep-based reports, pharmaceutical companies had had to re-evaluate the way they collect and report this info. They must consider all pieces of data needed for each report and ensure these are collected upstream at the time of interaction. It has proven difficult to gather this info after the fact which has made the sales rep’s recording responsibilities more important than ever.
Sales Rep State Reporting Resources
Nevada:
https://dhhs.nv.gov/HCPWD/Drug_Transparency_Reporting/Pharmaceutical_Sales_Representatives
Oregon:
https://dfr.oregon.gov/business/licensing/pharmaceutical-rep/pages/pharmaceutical-rep.aspx
Connecticut: