SOURCE: Cutting Edge Information

Cutting Edge Information

February 05, 2015 08:30 ET

Sunshine Act Disclosure Requirements Highlight Importance of Fair Market Value

RESEARCH TRIANGLE PARK, NC--(Marketwired - February 05, 2015) - Historically, life sciences companies have sought to reimburse thought leaders using reasonable, fair market value (FMV) rates. However, according to pharmaceutical intelligence provider Cutting Edge Information, the Physician Payment Sunshine Act and other reporting- and rate-based legislation have added additional layers of scrutiny to payment practices. 

Under the Sunshine Act, companies working with US physicians are responsible for annually reporting physician payments to the Centers for Medicare and Medicaid Services (CMS). In Europe, 2015 marks the first year that the European Federation of Pharmaceutical Industries and Associations (EFPIA) will require its member companies to track physician payments. The Japan Pharmaceutical Manufacturers Association (JPMA) has also established physician payment reporting guidelines under guidance finalized in 2013. 

"Ultimately, regulations necessitating payment disclosures have transformed the use of physician FMV strategies from best practice to necessity in the life sciences industry," said Sarah Ray, senior research analyst at Cutting Edge Information. "Even in countries such as the Philippines where no equivalent legislation yet exists, companies are still obligated to internally assess the payments they provide to local physicians. Moreover, these companies may find that they are directly affected by existing legislation if they choose to work with KOLs from countries with reporting regulations."

According to Cutting Edge Information's newest report, "Global Key Opinion Leader Compensation 2015: CEI's Annual Review of Fair Market Value," company size and geographic region may factor heavily into a company's FMV structure. Unsurprisingly, large companies tend to offer slightly better compensation rates than do their smaller counterparts. Moreover, companies in the United States may offer more competitive hourly rates than their counterparts in either Europe or Canada.

Yet, ultimately, the aim of FMV structures is clear: companies are seeking measures to recruit skilled medical experts who support their activities via consistent and defensible fee schedules that will withstand scrutiny from compliance teams and regulators.

"Global Key Opinion Leader Compensation 2015: CEI's Annual Review of Fair Market Value," available at, provides an introduction to fair market value metrics and discusses the implications of recent physician payment disclosure requirements. The report's analysis also examines how companies may select the key opinion leaders with whom to work and provides sample rates of how teams may reimburse selected influencer types. Highlights from the report include:

  • Sample base hourly rates: by region, company type, KOL tier designation and physician specialty area
  • KOL selection criteria, including a discussion of standardized rate cards
  • A review of the Sunshine Act and similar physician payment disclosure requirements

Additionally, Cutting Edge Information's FMV service provides data for different thought leader activities based on specialty, geographic region and tier. Data is available for 117 countries, 109 specialties and 63 non-specialties. Go to to learn more. 

Image Available:,_by_Georgrap-1269672296346.jpg

Contact Information