Simplify spend transparency and sampling for mid-level providers

There are now more than 325,000 nurse practitioners (NPs) licensed in the U.S. and 140,000 certified physician's assistants (PAs). These mid-level providers are increasingly key to healthcare interactions with patients, especially in certain therapeutic areas where we may see clinical nurse specialists working with the patients more often than the physician. Not including these important contacts in your marketing mix or your business plans could limit your reach. But do you have a robust customer data foundation in place to effectively engage with mid-level providers in a sea of constantly changing compliance requirements?

Spend transparency reporting grows increasingly complex

The United States Sunshine Act covers reporting requirements for various types of recipients including MDs and DOs, as well as other types of healthcare providers, such as dentists, optometrists, podiatrists, chiropractors, CMS physicians, and teaching hospitals. But spend transparency regulations have become more challenging to manage with new additions to the covered recipient list required by the Support Act (often called the Sunshine Act part two). This legislation adds mid-levels to your list of covered recipients reporting beginning in March 2022.

It may sound easy enough, but reporting on these newly covered recipients creates a unique set of data challenges. The Validated Prescriber List (VPL) provided by CMS identifies the covered recipients under the original Sunshine Act. But now you need to manage a second list of covered recipients called the Preliminary Non-Physician Practitioner List (PNPPL). CMS acknowledges that some contacts might not be included on that list, and the ball is in your court to correctly identify them and manage compliance. The provided list is directionally correct, but accurate and comprehensive reporting falls on the shoulders of life sciences organizations.

The newly covered recipients include PAs and NPs, as well as certifications, such as certified nurse midwives (CNM) and certified registered nurse anesthetists (CRNA). These certificates can be earned by both advanced and non-advanced practice registered nurses, so if a provider is certified by a recognized board or organization, you now need to include them in your reporting. For example, three different certifications can be used to become a midwife in New Jersey, and any one of those are recognized by CMS as entities that need to be reported on at the end of the year.

State-specific sampling requirements create sampling landmines

Similarly, compliance requirements around mid-level sampling continue to evolve. Sample eligibility can differ across states, which enforce a variety of requirements by degree, certification, or controlled substance. For example, a certified nursing specialist (CNS) may have completely different capabilities with respect to both controlled and non-controlled substance sampling and prescriptive authority depending on their state. Various Collaborative Agreements between doctors and mid-levels further complicate state-specific sampling regulations.

Mid-level reference data simplifies compliance tracking

What can be done to help alleviate the confusion? Some organizations avoid sampling mid-levels, but strong customer data may help evolve these corporate policies as mid-levels become a more prominent part of the healthcare ecosystem.

To more easily manage these compliance requirements, Veeva OpenData U.S. tracks all of the various sampling and prescriptive authorities for all eligible providers - regardless of level. Take a step back as you review your account management strategies: what's the holistic view of an office? Understand the affiliations of the HCPs - mid-levels included - for a given practice, confident that your team is operating in compliance with evolving spend transparency and sampling requirements.

Having the right solution to manage customer reference data can help guide compliant interactions with mid-level providers. Read more about state-specific compliance challenges.

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