Promotional Activity – Including/Excluding Healthcare Professionals

Over the past several years a number of Pharma companies have developed processes and procedures to ensure that promotional activities, personal and non-personal, are targeted appropriately. Customers are either “included or excluded” based on the specialty of a healthcare professional (HCP) and a product’s approved indication(s). As noted in a variety of recent legal and financial settlements, the costs associated with inadequate promotional controls is extremely high.

Role of the Customer Masterfile

The long term success of an inclusion/exclusion program centers on the customer masterfile. Over time the number of duplicate entries in a customer masterfile can increase for various reasons (mergers, multiple entry points utilizing various business rules, etc.). Duplicates can easily occur without strong processes and procedures, often with multiple entries having conflicting physician specialties. Resulting data issues and inconsistencies have a direct impact on the effectiveness of the quality of inclusion/exclusion efforts that organizations are looking to employ for compliance and other business reasons.

Organizations addressing challenges in this area need to access and potentially implement system enhancements to the customer masterfile (including related processes and procedures), develop business rules for physician specialties at a product level, and coordinate the scrubbing of existing entries in the customer masterfile to eliminate duplicates.

Data integrity supported by Business Rules

Developing and documenting business rules for inclusions/exclusions based on physician specialty and product indication(s) is a rather straight-forward process. However, challenges arise because numerous functions within a Pharma organization (Field Sales, Inside Sales, Help Desk/Information Center, Digital channels, Medical Affairs, etc.) are typically permitted to create new customer entries. A lack of consistent and uniformed business rules across these touch-points can introduce a level of unanticipated complexity and can compromise data quality.

CRM systems provide opportunities for users to create new and/or modify existing customers. Sales representatives are uniquely positioned to gain knowledge about their customers in “real time” and companies can benefit by utilizing this information in a timely manner.

• To properly manage this decentralized input, consideration should be given to the development of business rules that require sales representatives to search for the healthcare professional (HCP) on his/her PC or tablet to determine if the HCP already exists, possibly at another location or using a different naming convention.
• When a new HCP entry is required it is strongly recommended that specific (core) information be entered prior to the request being processed. Core data may include: First name, last name, office address, office phone number, state license #, and physician specialty.
• CRM systems also have a robust governance mechanism. New entries should not be added to a call plan without proper verification and approval through various internal processes. From an IT standpoint, this governance module needs to be developed and integrated into the current CRM workflow.

The expansion of digital promotions has added a challenging level of complexity to the process. In most cases, new customer profiles can be created on-line by the healthcare professional attracted to a website or offering. From a compliance perspective, it is important that profile data entered by a healthcare professional via a digital channel be consistent with the standards used by other channels. This positions the company to effectively validate and manage entries in the customer master, proactively managing duplicates. Further, if possible, it is advantageous to have real-time validation of state license numbers and physician specialty to manage inclusion/exclusions.

System Integration provides an avenue to ensure compliance across the enterprise

Feeds to/from the customer masterfile to various systems need to be analyzed and points of integration coordinated. There are numerous additions and deletions of customers each year due to newly licensed healthcare professionals, changes in specialties, relocations, retirements, deaths, etc. With numerous systems relying on timely and accurate updates to assist in compliance efforts, housing HCP data in a central repository with tightly integrated feeds to/from other systems positions organizations to run effectively and maintain standards to better serve all impacted stakeholders.

Ideally all systems involved in the inclusion/exclusion process need to be intelligent enough to apply correct restrictions with minimal instructions and maximum flexibility.

Axtria Inc. – Ingenious Solutions

Axtria Inc. is an advanced analytics organization with significant experience in this area. Axtria offers both consultative and systems solutions that will assist companies manage inclusions/exclusions in a compliant manner.

Have you included all your inclusions and excluded all your exclusions? If you’re not sure, contact us to compare notes.