Imada covered the topic that's on everyones mind, the AMP final rule. Her advice? Start by assembling the right team, it's important to keep an open line of communication throughout the entire process. Also, in terms of tackling the uncertainty of the AMP final rule, analyze, prioritize, and implement. It's imparative to analyze all possible outcomes to ensure a smooth transition when the final rule is released, prepare ahead of time! Also, prioritizing will help you save time, as well as stay organized, which are both important components to approaching the final rule.
One of the later afternoon Methodology sessions, Government Pricing Policies & Methodologies --Methodology Foundation of Compliance, was led by John Shakow, King & Spalding. Shakow covered important topics such as, why documentation is a compliance requirement, as well as a practical necessity. He also discussed the elements of a comprehensive set of methodologies, and the best practices.
So why is documentation a compliance requirement? Price reporting methodology documents are always at the top of the list of documents requested from auditors, investigators and prosecutors, that's why it's necessary to keep all documents organized and updated. The legal resources on which we rely to govern pricing reporting are detailed and exacting, but not nearly detailed enough to reliably and consistently guide the calculations. Comprehensive, thoughtful and well-articulated methodological documents are our first defense against allegations of ‘reckless’ treatment in price reporting.
Shakow also reviewed the elements of a comprehensive set of methodologies: product master, price type narratives, inclusion/exclusion schema by price type (transaction type), reasonable assumptions by price type, non-price type methodologies, record of communications with authorities and implementation SOPs/crosswalks to system coding.
Specific Methodology documents are critical tools in coding and testing GP systems. The creation and maintenance of these methodologies is an internal education tool for use by personnel new to GP, the certifier, and all other business related aspects, so if there are any errors it will impact various groups.
Shakow closed with some advice about the final rule. While you're waiting for the final rule, use it as an opportunity to examine, review and tighten methodology documentation, especially because it is highly unlikely the Final Rule will be retrospective in its application.
Stay tuned for our recap of the final day of MDRP!