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interactRx™: Identifying fair market value for physician compensation

A cloud-based solution for FMV rates

Are you looking to more effectively identify fair market value (FMV) for physician compensation? Carefully track health care provider (HCP) rate activity? And have reporting and analytics at your fingertips? Look no further than interactRx™.

A fair market value tool

interactRx is a cloud-based FMV solution that provides:

  • Centralized on-demand access to your company's FMV rates in a secure web tool, allowing you to track HCP rate activity
  • Workflows for routing and approval of tiering and exception requests
  • Reporting analytics for fast and careful analysis of your FMV data

This FMV tool exports the full rate history and inspection trail of your company's FMV activity, including exception requests. It efficiently integrates with your company's and your vendors' existing systems. And its multi-user and multi-country capabilities facilitate centralized management and control of international FMV.

Built on the foundation of Deloitte & Touche LLP's demonstrated methodology and experience serving the life sciences industry within the research, commercial and compliance functions, interactRx could be just the prescription you need to effectively determine fair market value for physician compensation.

Flexible workflow configuration

interactRx is configurable to provide guidance to the engagement and contracting processes with HCPs. This tool goes beyond rate cards to offer an efficient platform for facilitating HCP engagement and contracting at consistent FMV rates.

Workflow approvals can be enabled for the following items:

  • Rate request (within FMV or operational rate)
  • Rate exception request (exceeds FMV or operational rate)
  • HCP creation request
  • HCP tiering request

Each enabled workflow may have the following approvals built-in:

  • Manager approval: Defaults to the requester's manager but may be overridden when submitting a request
  • Approval groups 1, 2, and 3: Approvals are assigned to one or more individuals, who may accept the request. Approval groups 1, 2, and 3 proceed in series
  • Forwarding and return: Approver may forward the request to another approver or send the request back to the requester for changes
  • Email notifications: Administrator/authorized user receives notification email for each request

FMV Dashboard–Illustrative Example

Accessible

Full and ongoing access to the latest data for best-in-class reporting

Our team will work closely with you to:

  • Guide you through a complex process of the intent and scope of the regulations 
  • Discuss options to create HCP contracting processes to help you defend and implement the changes 
  • Help you reduce disruption of your business by providing a consistent and streamlined methodology that satisfies both regulatory and market expectations

As part of your core business, you contract with third parties—including HCPs and other knowledgeable professionals—to compensate them for consulting activities to provide guidance, educating the physician and patient communities that span research and development, clinical, medical affairs, and sales and marketing.

Such arrangements that aren't priced at FMV may have the real or perceived risk of leading to inappropriate influence or inducement. Regulatory risks related to payments include allegations of kickbacks, bribery, and violations of the Foreign Corrupt Practices Act. Increased attention to FMV by regulators is evidenced by recent regulatory actions (corporate integrity agreements, global transparency regulation, government investigations, etc.).

As a result of recent regulatory actions, there is heightened awareness and exposure as FMV data is publicly available and faces an increased level of scrutiny. A documented approach can help you determine FMV and reduce risk related to the appearance of inappropriate kickbacks or incentives to HCPs.

Get in touch

Mark A. DeWyngaert
Managing director | Life Sciences
Deloitte & Touche LLP
+1 203 253 6203

Paul Silver
Principal │ Life Sciences Regulatory and Operational Risk
Deloitte & Touche LLP
+1 404 631 2157

Laura Skinner
Senior manager │ Life Sciences Regulatory and Operational Risk
Deloitte & Touche LLP
+1 512 745 7338

 

Jack Tanselle
Managing director │ Life Sciences Regulatory and Operational Risk
Deloitte & Touche LLP
+1 317 656 2452

 

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