Aggregate Spend Reporting and Sunshine Act Compliance

The Sunshine Act has had a significant impact on Alere because they are a large company with many entities in the U.S. They had to request monthly reports from each of their entities and then aggregate, standardize, and check all of this data before it is submitted to the CMS. This process creates considerable effort for their compliance and finance teams. Mendix's application platform give them the ability to coordinate with a number of different internal systems to gather and store data.

There are other factors too, such as multiple reporting templates for research and non-research payments. Some of their entities make both types of payments, so they must run two separate reports. It generates additional administrative work and did not have the internal bandwidth to manually manage aggregate spend reporting.

Challenge

Alere evaluated several Platform as a Service providers for developing an application to support this business process and decided that the Mendix platform was the best fit for their needs. Mendix was upfront and responsive throughout the process.

While CMS had not yet announced the final rule, they knew they had to move quickly and remain nimble to support the ever-evolving requirements. They were confident that Mendix's application platform would enable them to build what they needed and when they needed it, while providing the flexibility to fine-tune their application along the way. Since they could deploy in the Mendix cloud, they did not have to worry about any hardware or infrastructure.

Solution

Using Mendix's application platform, Alere custom built a single application to manage their aggregate spend reporting. They now have one central location to capture and standardize data so that they can generate timely and accurate reports in order to prepare for Sunshine Act requirements.

Using Mendix's application platform, we custom built a single application to manage our aggregate spend reporting. We now have one central location to capture and standardize data so that we can generate timely and accurate reports in order to prepare for Sunshine Act requirements.

Christine Meyers

Associate Director, Corporate Compliance, Alere

Each month, various entities run reports and upload them to their aggregate spend portal, using Mendix's application platform. They are notified whether the data is accepted or rejected based on the reporting template criteria. If the data is not reported properly, a report is generated to include line item validation errors so that necessary corrections can be made. Once reports are accepted, an instant notification is received and then he reported data can be reviewed. They have the ability to run reports by entity or collectively by payments. The whole process is much more automated, thereby reducing administrative work. It is much easier to request monthly reports and to track when reports are uploaded to the aggregate spend portal. Without this centralized spend portal, they would be constantly following up with finance contacts and checking on monthly reporting status.

Results

Aggregate spend reporting may be too burdensome to do manually, especially for large, complex companies with multiple accounts payable and/or expense management systems. The ability to have one location to accept and store data from many different systems will greatly ease the administrative burden of the reporting requirements.

It’s also important to get buy-in from senior management. Understanding the requirements and penalties of the Sunshine Act and how they apply to Alere as a medical device manufacturer, senior management supported the need to build an aggregate spend portal to facilitate meeting the requirements. Their finance and compliance teams are all very busy, but everyone understands the importance of this compliance requirement. Alere worked together with Mendix to build an aggregate spend solution that assisted in complying with the Sunshine Act requirements in an efficient and effective manner.

Many companies are just waking up to the reality of the Sunshine Act and need to act now to get the right systems and processes in place. That’s where a platform like Mendix can help. It allowed Alere to deliver what the business needed quickly, and then make changes on the fly.