The manner in which life sciences companies interact with healthcare practitioners and healthcare organizations continues to evolve due to the complexity associated with aggregate spend and state disclosure laws, mandated compliance programs, gift prohibition laws, and the recently passed Federal Patient Protection and Affordable Care Act (PPACA). Because of this level of complexity and the constantly changing regulatory environment at the state and federal level, an adequately trained field sales force is as important as ever.

Training specific to the field sales force should not only focus on state and federal disclosure, compliance, and prohibition laws, but also on company-specific operating procedures governing compliance with these laws. The training program should occur during the initial training phase of a new employee and continue on an ongoing basis.

Besides the obvious benefits to overall compliance of the organization, a field force that understands the regulatory requirements imposed on life science companies (e.g. not providing gifts or meals where prohibited by law) can accurately relay this information to its customers where appropriate. This benefit will become even more evident in the upcoming years due to the national public disclosure requirements associated with PPACA for aggregate spend.

The field sales force is the company’s primary face to the customer, and these customers may have questions, concerns, etc., specific to what financial transactions are going to be made public and when. This training can also be leveraged by inside sales teams and customer service representatives because they will more than likely receive inquiries from healthcare practitioners and healthcare organizations.

Additionally, public relations and communications departments can utilize the training curriculum as well since any publically disclosed financial transactions between life sciences companies and their customers may cause questions from the media and patient advocacy groups. The public relations/communications departments will need to quickly respond to these questions with a planned response on the legitimacy of relationships with customers.

Even with the best training program, there is always room for error. For this reason, there also needs to be importance placed on the integration between an aggregate spend disclosure and reporting solutions and CRM solutions. Transparency is as important to the field force as it is to the compliance team. The field sales force should be constantly updated through their CRM solution on attainment towards spending limits as well as alerts for potential non-compliance with sales and marketing compliance programs. These limits and alerts should factor in spending beyond what the field sales force controls in order to give them a 360 degree view of the spending between all departments, other field sales force members and third parties acting on behalf of their company and individual healthcare practitioners/organizations. By having this aggregated information at the fingertips of field sales representatives, a company can ensure that before a field sales representative spends anything on a customer, the customer isn’t close to a spending cap or that a specific type of spend isn’t in violation of a prohibition law or company procedure.

  • Bill Buzzeo

    Bill Buzzeo is an authority on regulatory requirements facing today's pharmaceutical industry, specifically those involving the Prescription Drug Marketing Act (PDMA); international, federal, and state transparency and reporting requirements; and the Controlled Substances Act (CSA).

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