While compliance with the Sunshine Act is an obligation for life sciences companies, and multinationals must comply with similar legislation in the European Union, and increasingly in other regions, the question is whether transparency resourcing should be a core capability or skill set within organizations.
In the United States, large sums of payments have been reported under the Sunshine Act, including $10.03 billion in payments and ownership and investment interests in program year 2019, linked to 614,910 physicians and 1,196 teaching hospitals; and $9.03 billion in program year 2020, linked to 486,975 physicians and 1,212 teaching hospitals. The 2021 data are not yet available.
Against this backdrop, many companies are looking once more at the internal resources they dedicate to transparency. At present, knowledge and experience in this area tend to be concentrated among a few specialist employees, such as Compliance Operations, Finance, and IT staff. Historically, companies built this function in-house, often with home-grown systems following corporate integrity agreements or other investigations in the early 2000s.