Potentially Burdensome Reporting Obligations Ahead for Industry Interactions with APRNs in Connecticut

Cooley LLP
Contact

The Connecticut Department of Consumer Protection (Department) recently released its Expenditure Disclosure Form for manufacturers subject to section 75 of Public Act 14-217, which requires manufacturers of a covered drug, device, biological, or medical supply that provides a payment or transfer of value to an advanced practice registered nurse (APRN) practicing in the state to submit the information required by the Department on a quarterly basis.  The first report covering the period January 1, 2015 to March 31, 2015 is due July 1, 2015.  All reports must be submitted via email to DCP.DrugManufacturers@ct.gov.

Significantly, payments and transfers of value will not be reported to the Department in a consolidated form. Rather, an Expenditure Disclosure Form must be completed and submitted for each APRN to whom the manufacturer provides a reportable payment or transfer of value, potentially creating a significant administrative burden for manufacturers and the Department each quarter.  The following information must be provided on the form: name of manufacturer; first and last name of recipient; medical license number of recipient; Connecticut controlled substance registration (if applicable); date the expenditure was incurred; value/amount of expenditure; nature of the expenditure; purpose of the expenditure; FMV payment description; up to 5 prescribed products to which the expenditure relates, including product type (e.g., pharmaceutical, biologic, medical device, combination product) and product name; name and email address of person completing the form.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Cooley LLP | Attorney Advertising

Written by:

Cooley LLP
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

Cooley LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide