retrospect and looking forward: a review of two full years of open payments data and media coverage...

Retrospect and Looking Forward A Review of Two Full Years of

Open Payments Data and Media Coverage

T H E I N D I C A T I O N S F O R T H E F U T U R E

Thomas Sullivan

• Former political consultant who founded Rockpointe, Inc., a bio-medical education company in 1995

• Founder CME Coalition and Co-Founder ACRE

• Editor of Policy and Medicine

• Publisher Life Science Compliance Update

Agenda

• Review 2014-2015 Open Payments Data

• Discuss Media on Open Payments week of 2015 release

• Evaluate Prosecutions Using Open Payments

• Deliberate the CMS Questions on Open Payments

• Assess Congressional Actions on Open Payments

• Global Ag Spend and Media

Google Trends

The Data

Open Payments Data Summary

Overall2013

(5 Months)2014 2015

Difference 2014-2015

General Payments $1,010,000,000 $2,640,000,000 $2,600,000,000 -1.52%

Research Payments $1,810,000,000 $3,790,000,000 $ 3,890,000,000 2.64%

Ownership $1,080,000,000 $1,060,000,000 $1,030,000,000 -2.83%

Total 3,910,000,000 $7,490,000,000 $7,520,000,000 0.40%

Physician Primary Type

2015 # Payments

2014 Payments

Average2015 #

Payments2015

PaymentsAverage

Medical Doctor 31,324 $89,423,394 $2,855 43,760 $78,975,572 $1,805

Chiropractor 1 $7,200 $7,200 5 $2,984 $597

Doctor of Optometry 1,564 $3,134,278 $2,004 2,297 $2,429,218 $1,058

Doctor of Dentistry 290 $1,985,620 $6,847 247 $1,510,167 $6,114

Doctor of Osteopathy 642 $1,641,143 $2,556 1,735 $2,493,968 $1,437

Doctor of Podiatric Medicine

252 $1,681,617 $6,673 267 $949,250 $3,555

2015 Open Payments Data

• Total payments are effectively the same from 2014 - 2015 at $7.47B v $7.52B

• Number of physicians receiving a payment is static YoY at 618,000

• Total number of records published has shows no growth at 11.9M

• Average payment received by physicians (total payments/no. physicians receiving payment) has no differential at $12,120 in 2014 against $12,168 in 2015

• Only real change is in the number of companies reporting under the Physician Payments Sunshine Act– which has seen a decrease by 8% to 1456

https://en.wikipedia.org/wiki/Physician_Payments_Sunshine_Act

Key Year-on-year Open Payment Data Changes –All Payment Categories

All Payment Categories2013* 2014 2015

Annual Value ($ Billion) 3.91 7.49 7.52Normalized - Monthly Value ($ Billion) 0.78 0.62 0.63% Change YoY in Normalized Monthly Value -20% 0%

No. of Physicians Receiving Payments 480,000 618,000 618,000% Change YoY 29% 0%

Av. Payment per Physician Claiming in $ 8,146 12,120 12,168% Change YoY 49% 0%

No. of Companies Making Payments 1,392 1,580 1456% Change YoY 14% -8%

No. of Records Published in Millions 4.46 11.86 11.9Normalized - Monthly No. of Records Published 0.89 0.99 0.99% Change YoY in Av. Monthly Records Published 11% 0%

Nature of Payment Total Payments 2014 Total Payments 2015 % Difference

Research $3,787,943,220.60 $3,886,303,059.20 3%

Royalty $834,556,866.77 $949,742,341.19 14%

Services (Speaker) $621,957,768.01 $526,754,069.44 -15%

Consulting Fee $385,967,512.93 $378,323,486.10 -2%

Food and Beverage $233,190,961.08 $235,938,916.46 1%

Travel $185,790,269.38 $187,397,740.43 1%

Grant $89,452,394.10 $86,994,594.39 -3%

Ownership or Investment $53,435,230.64 $51,452,206.45 -4%

Education $70,146,029.36 $50,176,956.66 -28%

Honoraria $71,882,285.88 $36,574,555.96 -49%

Speaker (Non accredited) $23,262,951.78 $29,005,116.79 25%

Charity $10,159,500.17 $23,001,229.00 126%

Gift $30,258,066.48 $21,044,170.28 -30%

Space rental $21,112,768.42 $20,737,114.44 -2%

Speaker (Accredited) $8,179,406.59 $6,428,071.19 -21%

Entertainment $477,895.36 $378,733.44 -21%

Nature of Payments

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

120%

140%

$0.00

$500,000,000.00

$1,000,000,000.00

$1,500,000,000.00

$2,000,000,000.00

$2,500,000,000.00

$3,000,000,000.00

$3,500,000,000.00

$4,000,000,000.00

$4,500,000,000.00

Total Payments 2014 Total Payments 2015 % Difference

Total Payments by Specialty

$0.00 $2,000,000.00 $4,000,000.00 $6,000,000.00 $8,000,000.00 $10,000,000.00 $12,000,000.00

Internal Medicine

Psychiatry

Ophthalmology

Hematology & Oncology

Family Medicine

Dermatology

Other Service Providers/ Specialist

Cardiovascular Disease

Medical Oncology

Rheumatology

Orthopaedic Surgery

Endocrinology, Diabetes & Metabolism

Optometrist

2015 2014

129%

115%

67%

-55%

Hospitals

Research General

2014 2015Difference2014-2015

2014 2015Difference2014-2015

J&J (Janssen Companies Only)*

$99,175,296 $111,649,444 11.2% $64,840,821 $70,115,410 7.5%

Novartis $281,779,639 $513,394,378 45.1% $20,255,905 $25,719,817 21.2%

Genentech/Roche $110,128,328 $144,510,028 23.8% $274,806,796$325,804,12

515.7%

Pfizer $282,002,287 $391,734,059 28.0% $53,805,657 $44,676,784 -20.4%

Sanofi** $175,088,490 $106,279,034 -64.7% $22,740,225 $29,422,634 22.7%

Merck $107,427,067 $127,975,501 16.1% $26,981,143 $34,391,209 21.5%

Glaxo Smith Kline $179,464,140 $106,563,382 -68.4% $36,280,378 $35,840,379 -1.2%

Astra Zeneca $157,462,850 $222,360,795 29.2% $72,904,958 $54,071,173 -34.8%

Bayer $12,517,096 $21,399,765 41.5% $10,126,449 $11,068,802 8.5%

Giliad $65,944,757 $45,394,349 -45.3% $31,669,797 $36,830,535 14.0%Sanofi - is reported under 2 US entities

Janssen (Biotech, Pharma, Products, R&D, Scientific Affairs)

Research Payments

Specialty Research

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

Internal Medicine Psychiatry &Neurology/Psychiatry

Ophthalmology Hematology &Oncology

Family Medicine Dermatology Other ServiceProviders/ Specialist

Cardiovascular Disease

2014 Payments 2015 Payments % Difference

Research Payments by State

-20%

-15%

-10%

-5%

0%

5%

10%

15%

20%

25%

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

$300,000,000

$350,000,000

$400,000,000

$450,000,000

$500,000,000

CA TX FL MA NY PA NC OH IL TN MI

2014 Research 2015 Research Percentage

Research by City

-50%

0%

50%

100%

150%

200%

250%

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000


Research Payments by Company

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

120%

140%

$0

$100,000,000

$200,000,000

$300,000,000

$400,000,000

$500,000,000

$600,000,000


Teaching Hospital Research

-50%

-40%

-30%

-20%

-10%

0%

10%

20%

30%

40%

$0

$20,000,000

$40,000,000

$60,000,000

$80,000,000

$100,000,000

$120,000,000


General Payments

Key Year-on-year Open Payment Data Changes -General Payments

General Payments

2013* 2014 2015

Annual Value ($ Billion) 1.01 2.64 2.6

Normalized Monthly Value ($ Billion) 0.20 0.22 0.22

% Change YoY in Normalized Monthly Value 9% -2%

No. of Records Published ($ Million) 4.16 11.18 11.13

Normalized - Monthly No. of Records Published 0.83 0.93 0.93

% Change YoY 12% 0%

Ratio Disputed/Non-Disputed No. of Payments 0.00022 0.00013 0.00011

% Change YoY Ratio -41% -18%

Ratio Disputed/Non-Disputed $ Values 0.00235 0.00128 0.00287

% Change YoY Ratio -45% 123%

General Payments by Month

0

200000

400000

600000

800000

1000000

1200000

$0.00

$50,000,000.00

$100,000,000.00

$150,000,000.00

$200,000,000.00

$250,000,000.00

$300,000,000.00

$350,000,000.00

Au

g-1

3

Sep

-13

Oct

-13

No

v-13

Dec

-13

Jan

-14

Feb

-14

Mar

-14

Ap

r-1

4

May

-14

Jun

-14

Jul-

14

Au

g-1

4

Sep

-14

Oct

-14

No

v-14

Dec

-14

Jan

-15

Feb

-15

Mar

-15

Ap

r-1

5

May

-15

Jun

-15

Jul-

15

Au

g-1

5

Sep

-15

Oct

-15

No

v-15

Dec

-15

Payments Number of Payments

General Payments by State

-40%

-35%

-30%

-25%

-20%

-15%

-10%

-5%

0%

5%

10%

$0.00

$100,000,000.00

$200,000,000.00

$300,000,000.00

$400,000,000.00

$500,000,000.00

$600,000,000.00

$700,000,000.00

CA NY TX FL MA PA TN OH IL AZ GA NC


General Payments by Company

-50%

0%

50%

100%

150%

200%

250%

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

$300,000,000

$350,000,000


General Payment Companies with High % Differences

Company Name Total Payments 2014 Total Payments 2015 % Difference

ABLATIVE SOLUTIONS, INC. $155 $190,909 123067%

RHODES PHARMACEUTICALS L.P. $964 $768,774 79689%

IMPLANT DIRECT SYBRON INTERNATIONAL LLC

$3,748 $1,282,207 34113%

THE BINDING SITE INC. $441 $149,530 33788%

TRICE MEDICAL, INC. $157 $34,087 21592%

HENRY SCHEIN MEDICAL SYSTEMS, INC. $13 $2,469 18734%

RELIANCE MEDICAL PRODUCTS, INC. $152 $24,158 15766%

ADVANCED CIRCULATORY SYSTEMS INC.

$39,231 $5,855,724 14826%

OSSUR AMERICAS., INC $60 $7,307 12165%

THEKEN SPINE, LLC $2,499 $209,645 8290%

FDA Approvals Explain Differences

General Payments by Pharma Product

0%

100%

200%

300%

400%

500%

600%

0

20,000,000

40,000,000

60,000,000

80,000,000

100,000,000

120,000,000

140,000,000

160,000,000

180,000,000

200,000,000


Travel by City

-25%

-20%

-15%

-10%

-5%

0%

5%

10%

15%

$0

$1,000,000

$2,000,000

$3,000,000

$4,000,000

$5,000,000

$6,000,000

$7,000,000

$8,000,000

$9,000,000

$10,000,000


$2,037$1,989

$981

$6,630

$2,156

$3,091

$3,972

0

1000

2000

3000

4000

5000

6000

7000

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

NovartisPharmaceuticals

Corporation

ValeantPharmaceuticals

North America LLC

IrokoPharmaceuticals,

LLC

Ormco Corporation ACell, Inc. Implant DirectSybron

International LLC

Tulsa DentalProducts LLC

Total Amount of Payment US Dollars Number of Payments Included in Total Amount Average Payment

Faculty & Speaker Payments for Accredited & Non Accredited Education Programs Top Seven Companies

$4,503$4,372

$3,701

$5,083

$2,858

$3,459$3,528

0

1000

2000

3000

4000

5000

6000

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

$16,000,000

$18,000,000

Stryker Corporation Zimmer BiometHoldings, Inc.

Pfizer Inc. DePuy OrthopaedicsInc.

Boston ScientificCorporation

Merck Sharp &Dohme Corporation

Allergan Inc.


Consulting Fee Payments For Top Seven Companies

$2,193

$1,343 $1,447

$1,009

$1,931$1,750

$756

0

1000

2000

3000

4000

5000

6000

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

Intuitive Surgical,Inc.

KARLSTORZEndoscopy-America

Arthrex, Inc. Coloplast Corp Smith & Nephew,Inc.

MedaPharmaceuticals,

Inc.

ACell, Inc.


Education Payments by Top Seven Companies

$208

$68

$137

$52 $46

$83$73

0

100

200

300

400

500

600

$0

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

$90,000

AmericanOrthodonticsCorporation

Marco Ophthalmic,Inc.

Luminex Corporation Straumann USA LLC TERUMO MEDICALCORPORATION

Romark Laboratories,LC

Hitachi MedicalSystems America, Inc.


Entertainment Payments by Top Seven Companies

$17 $19 $15 $15 $21 $23 $20 $16 $19 $14 0

100000

200000

300000

400000

500000

600000

700000

800000

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

AstraZenecaPharmaceuticals

LP

JanssenPharmaceuticals,

Inc

Pfizer Inc. Novo Nordisk Inc BoehringerIngelheim

Pharmaceuticals,Inc.

AbbVie, Inc. SANOFI-AVENTISU.S. LLC

GlaxoSmithKline,LLC.

TakedaPharmaceuticals

America, Inc.

Actavis Pharma Inc


Food & Beverage Payments by Top Ten Companies

$2,109

$1,564

$1,970

$2,755

$1,495

$3,103

$5,013

0

1000

2000

3000

4000

5000

6000

$0

$1,000,000

$2,000,000

$3,000,000

$4,000,000

$5,000,000

$6,000,000

Gilead Sciences Inc Lundbeck LLC The Medicines Company Cardiovascular SystemsInc.

Aqua Pharmaceuticals W. L. Gore & Associates,Inc.

Hiossen, Inc.


Honoraria Payments by Top Seven Companies

Gifts Payments byTop Seven Companies

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

$18,000

$20,000

$0

$500,000

$1,000,000

$1,500,000

$2,000,000

$2,500,000

$3,000,000

$3,500,000

$4,000,000

$4,500,000

STRYKERCORPORATION

BENCO DENTALSUPPLY CO.

INTUITIVESURGICAL, INC.

CARL ZEISSMEDITEC, INC.

CRYOLIFE, INC. A-DEC, INC. ZIMMER BIOMETHOLDINGS, INC.

BECTON,DICKINSON AND

COMPANY

FUJIFILM MEDICALSYSTEMS USA, INC.

2014 2015 Average

Gift Details

Company Name 2014 2015Average

STRYKER CORPORATION $4,127,268 $1,953,868 $2,561

BENCO DENTAL SUPPLY CO. $1,967,700 $1,950,844 $119

INTUITIVE SURGICAL, INC. $1,398,650 $1,421,087 $8,882

CARL ZEISS MEDITEC, INC. $506,523 $1,337,217 $3,230

CRYOLIFE, INC. $1,206,684 $1,253,233 $17,903

A-DEC, INC. $1,207,502 $1,247,216 $185ZIMMER BIOMET HOLDINGS, INC. $0 $1,030,568 $2,029BECTON, DICKINSON AND COMPANY $184,912 $588,629 $2,172FUJIFILM MEDICAL SYSTEMS USA, INC. $761,705 $584,870 $10,084

Gifts – Comment Section Examples

• Customer Loyalty Programs

• Customer Appreciation Events

• Chocolates, Coolers, Cocktails, TV’s

• Xmas Gifts

• Jumpers

• 1 Company – Bottle of Makers Mark

Disputes – General Database

Year Number Total Value % Change

2013 911 $2,370,000

2014 1,435 $3,390,000

2015 1,172 $7,450,000-18% Number120% Amount

Total 3,518 $13,210,000

Percent of Payments

0.0133% 0.2114%

Disputes – Research Database

Year Number Total ValuePercent Change

2013 251 $3,380,000

2014 796 $10,980,000

2015 448 $5,900,000-44% Number-47% Amount

Total 1,495 $20,460,000

Percent of Payments

0.0057% 0.2135%

2015 Data Release

CMS data: In 2015, healthcare industry made $7B+

in payments, investment interests to physicians

ProPublica – Hospital Report

In 2014, about 77 percent of doctors at tiny Baystate Noble Hospital in Westfield received payments, mostly in the form of meals. Drug and device makers reported they made more than 200 payments each to Dr. Ira Nathanson and Dr. Arthur King. Most meals were under $25 and were given while company representatives provided

First, for information on industry payments to doctors, we turned to the federal government’s Open Payments system. All companies are required to submit this data, which is then made public under the Physician Payment Sunshine Act, a part of the 2010 Affordable Care Act. We used a file called “General payments,” which includes categories like promotional speaking, consulting, meals, travel, gifts and royalties.

Prosecution, Arrests, Settlements……

The class action plaintiffs used Insys’ own Open Payments data against the company to make the case that the payments essentially were kickbacks to induce prescriptions. Insysagreed to settle the lawsuit for $6.1 million in 2015.

Class Action Lawsuit

Dr. Gavin Awerbuch

In 2014 alone, Doctor-1 and Doctor-2 received over $147,000 and $112,000, respectively, in Speaker Program fees. During this same time period, Doctor-1 and Doctor-2 were also two of the largest prescribers of the Fentanyl Spray in the United States.

In 2014 alone, Doctor-1 and Doctor-2 prescribed, respectively, over $3 million and over $2 million worth of the Fentanyl Spray that was reimbursed by various private insurance companies, and over $1 million worth of the Fentanyl Spray that was reimbursed by Medicare.

California BMS Settlement• California Insurance Frauds Prevention Act

• The kickbacks used to entice physicians included box suites at sporting events with tickets, food, drinks, and parking provided; enrollment in a Lakers basketball camp for doctors and their children; pre-paid golf outings at golf courses; tickets to see Broadway plays in California cities; monetary incentives given to doctors with authority in prescription-drug formularies at hospitals and clinics; and lavish dinners, resort hotel trips, and concert tickets.

• Media notes in CA Insurance Commissioner includes links to Dollars for Doctors “Online information about money received by doctors”

• Pre 2007 Activities

• $30 Million

https://projects.propublica.org/docdollars/

Chicago Pfizer Opioid Settlement

Chicago Referral to Open Payments

• Under the Physician Payment Sunshine Act, passed as Section 6002 of the Affordable Care Act, pharmaceutical companies are required to disclose payments to prescribers and to teaching hospitals, as well as information about the nature, type, and purpose of the payments, for a period starting from August 2013. Data are available through December 2014 on the ProPublica.org website.

Chicago Complaint

• Speakers on ______bureau were among the more prolific prescribers of ______ opioids. PRESCRIBER R received $36,845 in payments from _______from 2011-2013, and his prescriptions resulted in $8,546.37 in payments from the City between 2011 and 2015 for ______opioids. PRESCRIBER CC received $8,250 in speaking fees for 2010, and his prescriptions resulted in $4,193 in claims from Nuc___ and Nuc___ ER.

Chicago - Agreement

• Disclose the risk of addiction to opioids, even when used as directed.

• Disclose that there are no adequate and well-controlled studies of the use of these products longer than 12 weeks. (This is especially important since opioids are frequently prescribed for long-term pain conditions.)

• Not promote opioids for any off-label or unapproved uses.

• Include information on opioid addiction and abuse in connection with its promotional efforts and communications, whether under the Pfizer brand or not.

• Maintain and promote a non-marketing website.

• Upon request, and to the extent it is educating prescribers about opioids, fund continuing medical education programs aimed at increasing prescribers' awareness of the risks of opioid addiction and abuse and helping prescribers identify signs of opioid addiction and abuse.

2016 Physician Fee Schedule –Open Payments Questions

• Nature of Payments?

• How Many Years?

• Monitoring Past Years Programs

• How Many Years if Relevant

• Yearly Registration?

• Considering adding reporting reasons for not reporting payments

• Pre-vetting requirement based on threshold or sample?

• Definition of Teaching Hospital?

• Regular uploads of data?

• Staff changes, Ownership, POD’s

• Streamlining

Comments Due September 6, 2016

Brief Look at UK Data

ABPI UK Reporting

2015 UK Pounds US Dollars

Grand Total £80,968,577 $123,072,236

Left Blank £56,580,822 $86,002,849

With Personal Data £24,387,755 $37,069,387

Summary of UK Data

• 70% of HCP payments selected to remain anonymous

• 30% had reported information

• Fewer Nature of Payments than US

• Data is easier to analyze, smaller dataset

• Payment amounts are significantly less than the US

ABPI UK Nature of Payments

2015 Data UK Pounds US Dollars

Contribution to costs of Events £23,993,375 $36,469,929

Registration Fees £2,499,124 $3,798,668

Sponsorship agreements with HCOs /3rd parties £16,021,545 $24,352,748

Travel & Accommodation £5,472,706 $8,318,513

Donations and Grants to HCOs £28,806,150 $43,785,349

Donations and Grants to HCOs £28,806,150 $43,785,349

Fee for service and consultancy £24,934,803 $37,900,900

FeesRelated expenses agreed in the fee for services or consultancy contract

£22,268,564 $33,848,217

£2,665,897 $4,052,163

Travel & Accommodation £342 $520

Joint working £3,234,249 $4,916,058

Joint working £3,234,249 $4,916,058

Specialty UK Pounds US Dollars

Nurse £2,617,309.21 $3,978,310

Oncology £1,887,557.25 $2,869,087

Haematology £1,885,226.91 $2,865,545

Pneumology £1,619,318.92 $2,461,365

Diabetes £1,607,100.83 $2,442,793

General Medicine £1,444,717.02 $2,195,970

Miscellaneous £1,221,357.89 $1,856,464

Cardiology £1,095,473.54 $1,665,120

Rheumatology £938,870.05 $1,427,082

Gastroenterology £929,236.33 $1,412,439

Neurology £806,936.20 $1,226,543

Healthcare Administration £765,535.22 $1,163,614Pharmacist £651,794.81 $990,728Ophthalmology £645,391.80 $980,996Dermatology £602,938.12 $916,466Urology £516,161.53 $784,566Psychiatry £499,500.73 $759,241

Name UK Pounds US Dollars

Ian Pavord £98,703 $150,028

Brian Lipworth £96,647 $146,903

John Gribben £90,109 $136,965

Mark Nelson £75,115 $114,175

Ernest Choy £68,935 $104,781

Marcus Drake £68,897 $104,724

Anita Hill £68,711 $104,441

Ashley Brown £64,847 $98,568

Paul Jones £64,135 $97,485

Anton Pozniak £62,143 $94,457

Lyndon Evans £61,568 $93,583

Sukh Singh £60,480 $91,929

Peter Ratcliffe £55,463 $84,304

Peter Hillmen £52,714 $80,126

Simon Travis £52,401 $79,650

John Harrison £51,740 $78,645

Nicholas Thatcher £51,490 $78,264

Catherine Harmer £51,046 $77,590

Company UK Pounds US Dollars

Pfizer Ltd £6,943,794 $10,554,567GlaxoSmithKline plc £5,704,678 $8,671,111AstraZeneca £5,499,063 $8,358,575Novartis Pharmaceuticals UK Ltd £5,016,062 $7,624,415Janssen-Cilag Ltd £4,862,484 $7,390,976Bayer Plc £4,312,210 $6,554,560Biogen Idec Ltd £3,466,763 $5,269,480UCB Pharma Ltd £2,987,607 $4,541,163Roche Products Limited £2,857,888 $4,343,989Novo Nordisk Limited £2,229,701 $3,389,145Sanofi Aventis £2,217,778 $3,371,022AbbVie Limited £1,857,482 $2,823,372Genzyme £1,678,806 $2,551,786Astellas Pharma Ltd £1,533,248 $2,330,537Gilead £1,468,482 $2,232,093Bristol-Myers Squibb Pharmaceuticals Ltd £1,465,509 $2,227,574Eli Lilly & Company Ltd £1,404,496 $2,134,834Merck Serono Ltd £1,389,132 $2,111,480Merck Sharp & Dohme Ltd £1,347,067 $2,047,543

Hospital UK Pounds US Dollars

King's College Hospital £424,243 $644,850

Churchill Hospital £382,962 $582,102

Chelsea & Westminster Hospital £360,031 $547,248

The Royal Free Hospital £359,303 $546,140

St James's University Hospital £356,945 $542,557

University College Hospital £349,200 $530,783

Addenbrookes Hospital £344,962 $524,342

Southampton General Hospital £338,037 $513,816

Queen Elizabeth Hospital £306,252 $465,503

The Royal Marsden Hospital £287,754 $437,385

Hammersmith Hospital £275,780 $419,185

Freeman Hospital £266,048 $404,393

University Hospital of Wales £256,142 $389,335St Bartholomews Hospital £249,991 $379,987The Royal London Hospital £248,707 $378,035Ninewells Hosp & Med School £243,473 $370,079

Summary

• Though the aggregate data remained the same, huge variations in company level data and inter company level data

• Not Much Media will be on just Open Payments – look for more tie in reports

• Look at your data, document your outliers

• More plaintiff attorneys and prosecutors will use open payments

• Look for changes in Open Payments 2017 Fee Schedule

• A bill may be yet passed on Reprints and CME

• The Global Ag Spend Movement is going to be HUGE!!!!

More Information

Thomas Sullivan

[email protected]

www.Rockpointe.com

www.policymed.com

www.lifescicompliance.com