take effect until 2012. Our public-policy guys are mon- itoring it, though.” Indeed, an online survey that Convene conducted
MEDICAL MEETINGS
in late February suggests that a majority of medical planners remain either uninformed about or unsure of how this portion of PPACAmight affect their meetings. Nearly 35 percent said it was too soon to tell, while 22 percent were entirely unfamiliar with the new requirements. (See the chart on p. 43.) Butawareness does appear to be growing.On a general level,
a recent survey on 2011 convention-marketing activities found that 97 percent of HCEA members think “legal/regulatory compliance” is very or extremely important—up from 82 percent in 2010. And the panel discussion at HCEA’s summit, as well as a similar dis- cussion before the meeting on an HCEA listserv, seem to have alerted more planners and associations to the specific issue of the PPACA provi- sion. “To be honest,we are just start- ing to look into this,” saidWanda Johnson,CMP, CAE, senior director of meetings and education for the Endocrine Society. “It doesn’t really go into effect until 2012, so the Sunshine Act is on the back of our radar screen; it’s not here in my face right now.” (Johnson was referring to the PPACA provision by the name of a previous version of the bill—the Physi- cian Payments Sunshine Act of 2009, which eventu- ally was folded into PPACA.) Johnson is correct about when the requirements take effect. Sec. 6002 of PPACA states:
On March 31, 2013, and on the 90th day of each calendar year beginning thereafter,any applicable manufacturer that provides a payment or other transfer of value to a covered recipient… shall submit the following information with respect to the pre-
ceding calendar year [with 2012 being the first]: The name of the covered recipient. The business address of the covered recipient and, in the case of a covered recipientwho is a physician, the specialty and National Provider Identifier of the
ON_THE_WEB
To read the entire HCEA background document cited in this article, “Collecting NPI Numbers: Healthcare Associations Are on the Frontline for Exhibitor Compliance with the PPACA,” visit www.hcea.org/ news/2011-0215-npi.asp.
To watch a video about PPACA’s
transparency reporting requirements from the law firm of Arnold & Porter, visit http://bit.ly/ebehgJ.
covered recipient. The amount of the payment or other transfer of value. The dates on which the payment or other transfer of value wasprovided to the covered recipient. Adescription of the formof the payment or other trans- fer of value. A description of the nature of the payment or other transfer of value. If the payment or other transfer of value isrelated to marketing, education, or research specifically to a covered drug, device, biological, or medical supply, the name of that covered drug, device, biological, or medical supply. Any other categoriesof infor- mation regarding the payment or other transfer of value the Secre- tary [of the U.S. Department of Health & Human Services] deter- minesappropriate.
A Numbers Game
This information must begin to be collected as of Jan. 1, 2012. So far, the focus for associa- tions that are in the know about this matter seems to
LATE IN THE GAME: From a “process and timeline standpoint,” the American Thoracic Society’s Michelle Turenne said, “it’s already too late” to capture attendees’ NPI numbers for 2012.
be the National Provider Identifier (NPI) number. “That’s the number that everybody’s talking about as being uniquely suited to this,” said Michelle Turenne, senior director of corporate alliances and development for the American Thoracic Society (ATS). “And it’s important. NPI is the number that will prob- ably be used for reporting.” The problem with that is, if exhibitors ask medical show organizers to help them obtain this information from attendees—including attendees’ NPI numbers— how will the associations go about this? And how much lead time do they need to figure it out? “That process has to startnow,”Turenne said.“We have to start educating our leadership, because we have to program our registration forms to capture a num- ber that, frankly, we’ve never been interested in before. From a process and timeline standpoint,… it’s already too late for our meeting.We should have been having this conversation a year ago to be able to provide data for 2012 reporting.” In a background document released in February,
HCEAagrees withTurenne:“HCEAhas learned that very few, if any, healthcare associations are currently collecting the NPI numbers of their healthcare pro- fessional attendees. Discussions withHCEA’s health- care associationmembers have shown that beginning to do so will require considerable quick planning and adaptation.” Those efforts, according toTurenne, probably will manifest themselves in the registration process, which