There are CRM solutions in the marketplace that can track promotional spend, even provide alerts when spend limits are being approached. This functionality is also available on mobile devices. Once documented, the data can be fed directly from the CRM solution into an aggregate spend solution to aggregate, process, and report the data to satisfy federal and state legislative requirements. That information can also be used internally for analysis of promotional spend for planning purposes.

Look for a CRM solution that:
• Captures and allocates expenses to all or selected call participants
• Captures the nature and purpose of the spend in accordance with US compliance laws
• Sends a warning when a spend threshold has been reached (if expenses are fed into the system)
• Seamlessly integrates with an aggregate spend solution

And of course, choose one that enables the user to access that same functionality on a mobile device.

The increase in the number and the complexity of laws is making it very difficult for companies to handle this reporting internally under most circumstances. Given all the differences in requirements across the laws, it has become quite burdensome to gather/organize data and prepare reports. For a small company with a minimal sales force that is not engaged in much promotion and advertising, it’s feasible to organize the data internally. However, it is usually more cost-effective to outsource the process to someone with a specialized solution to help meet disclosure compliance. These solutions can enable efficient data integration and cleansing as well as automated reporting that is continuously updated per current regulations. In addition, by outsourcing, companies can the focus on higher-value compliance tasks such as oversight, approval, auditing, and analysis

The new federal law adds another layer of complexity to the required reporting for life science companies. The federal law requires life science companies to track and report on a wide range of payments made to covered recipients, including healthcare practitioners and teaching hospitals (any payment/gift over $10 or $100 aggregate in a given year) which will be made publicly available via a searchable online database. These payments must be reported individually rather than simply disclosing the aggregate payments.

As with the many enacted and pending state disclosure laws, the federal law has yet a different required report format, specification codes, and disclosure requirements. And since the federal government does not use state identifier numbers, companies must move towards adopting a more universal customer ID, such as NPI.
In addition, there is the issue of preemption. The federal law may preempt existing state reporting rules and gift bans if the state laws are similar to or less stringent than the federal requirements. However, this condition does not displace state reporting requirements that are more rigorous than the new federal law. For example, some state laws have total bans on “gifts” to physicians regardless of dollar amounts, which would supercede the federal guidelines. Therefore, companies must be sure to stay up to date on all regulations to determine what their report requirements are.

The new federal law imposes significant financial penalties for noncompliance – up to $150,000 per year for unknowingly failing to report a payment, and up to $1 million per year for knowingly failing to report. Given the relatively short implementation timeline, companies need to start understanding the implications to their business now to start to efficiently and accurately collect data starting in 2012.

The shared SaaS option is the most cost-effective solution, with a lower monthly cost compared to the dedicated SaaS platform. However, given the recent advances in systems virtualization, the cost difference between the two models has decreased significantly compared to the early days of SaaS.

Another factor to consider is that a shared SaaS environment has fixed upgrade timing, whether it suits the client or not, while a dedicated SaaS environment allows the client to choose the upgrade timing within a time window, usually 90 days.

Finally, most SaaS vendors impose daily processing and data-load limits on their shared environment, while the dedicated option is generally not subject to these limits.