Sunshine Act / Open Payments

Compliance with the Open
Payments (formerly Sunshine Act)
using Gorilla

The Gorilla Expense T&E Solution includes the Sunshine Act module that allows for Representatives from Pharmaceutical, BioTech and Medical Device Companies to not just submit their T&E expenses but also allocate these expenses to the respective Health Care Provider (HCP) which includes the US National Provider Identifier (NPI) of the HCPs.

Per Federal law, these companies are required to capture the HCP information to be in compliance. Failure to stay in compliance may result in fines ranging from $10,000 to $1,000,000 annually.

You can also check out this popular infographic on ‘Shining Light on the Sunshine Act to understand requirements from the Centers for Medicare & Medicaid Services (CMS) for compliance to the Sunshine Act.

What is the Open Payments Program?

The Open Payments Program (formerly known as the Physician Payments Sunshine Act), administered by the Centers for Medicare & Medicaid Services (CMS) requires all U.S. drug and medical device manufacturers to report any benefits made to physicians and teaching hospitals with an annual value totalling $100 or greater, as part of the Affordable Care Act of 2009.

On February 1st, 2013, the CMS announced the final rules for implementing the Transparency Reports and Reporting requirements as part of the Patient Protection and Affordable Care Act (“ACA”), commonly referred to as the “Sunshine Act.”

As part of the Sunshine Act, companies will be required to capture data starting August 1, 2013, and submit the federal reports by March 31, 2014.

Failure to stay in compliance may result in fines ranging from $10,000 to $1,000,000 annually.

Who Must Comply?

In accordance with the new regulations provided by CMS, all manufacturers of drugs, devices, biological products, and medical supplies must provide an annual report to the CMS for payments, ownership, investment interests and other transfers of value (TOV) to physicians and teaching hospitals. This especially applies to:

  1. Drug Manufacturers
  2. Medical Supplies Manufacturers
  3. Medical Device Manufacturers
  4. Biological Product Manufactures


What Needs to be Tracked?

Any transfers of value (this includes travel, gifts, meals, honoraria and other costs) greater than $10, must be reported along with their itemized dates, values and the nature of each benefit. Gifts greater than $100 will be made public and published online.

How Can Gorilla Expense Help?

Our Automated Expense Management module for the Open Payments Program/Sunshine Act includes all the capabilities and tools to help companies maintain compliance. We provide:

  1. Ability to connect with any HCP data source at no extra cost. Customer can go with the in-house data sources as well as data sources available in the market via 3rd party providers like MedPro Systems
  2. Ability to allocate expenses to the respective health care provider (HCP), including NPI numbers
  3. Ability to associate Affiliates with HCPs and automatically remember the association for future use
  4. Ability to calculate per participant cost
  5. Reporting to slice and dice data by HCP, Spend by State and other formats for greater intelligence and compliance.
  6. In addition to standard reporting, customers can connect to our cloud-hosted database to write their own reports.
  7. Connection to 3rd party vendors like MedPro Systems for seamless federal reporting of aggregate spend.
  8. Ability to combine supporting documents like signup sheets with the receipt, all from within our application.

Latest and Comprehensive Integration of HCP Data
Since the company’s sales reps are responsible for allocating expenses to the correct HCP, Gorilla Expense makes their lives easier by providing access to the latest and comprehensive set of HCP data in the application by integrating with various 3rd party vendors.

Why Choose Gorilla Expense?

Gorilla Expense is well-positioned to understand and solve the unique challenges of Pharmaceutical, BioTech and Medical Device companies when it comes to being complaint to the Open Payments Program.

Expense Reporting for Sunshine Act Open Payments

HCP Allocation Screen in Gorilla Expense

Our solution has been designed to be flexible, user-friendly and most importantly customizable to the variety of requirements that companies face. We are not an off-the-shelf solution; instead we provide a solution that will conform to your requirements. And we do this while being more 10% to 40% more economical than our competitors, simply becuase our platform is easy to use & maintain and simple to configure / customize.

OK, I’m Very Interested. Where Can I Learn More?

Our friendly (and prompt) sales team would be more than happy to discuss your requirements / provide more info/schedule a live demo.

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