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Case Studies in the Implementation of a Physician Payment Disclosure Initiative Geralyn S. Ritter Vice President, Global Public Policy and Corporate Responsibility, Merck & Co., Inc. NATIONAL DISCLOSURE SUMMIT Friday, March 6, 2009. Trust Deficit.
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Case Studies in the Implementation of a Physician Payment Disclosure InitiativeGeralyn S. RitterVice President, Global Public Policy and Corporate Responsibility, Merck & Co., Inc. NATIONAL DISCLOSURE SUMMIT Friday, March 6, 2009
Trust Deficit As companies and as an industry, we will not succeed if we don't start closing our trust deficit. And we won't accomplish this simply with more effective education efforts or better communications. As an industry, we must rebuild the foundation of trust that we once had and the foundation of trust that we continue to deserve. - Richard Clark Chairman’s Address PhRMA Annual MeetingMarch 28, 2008
Disclosure as an Element of Corporate Responsibility • “Sunlight is said to be the best of disinfectants” -- Justice Louis Brandeis (Harper’s Weekly, December 20, 1913) • Merck’s Corporate Responsibility Report • 65 key performance indicators • Environmental, social and governance issues • Third-party grants transparency – initiated in 2008, expanded in 2009
History of Merck’s Physician Payment Disclosure Efforts Merck policies and practices to ensure integrity PhRMA Code of Interactions with Health Care Professionals Enhanced public attention to industry-prescriber interaction Consultation between Merck and physician organizations Merck 2008 endorsement of Physician Payment Sunshine Act
Approaching Physician Payment Disclosure Reviewed existing and proposed disclosure requirements and mechanisms Examined internal systems Deliberate and structured process of consulting with stakeholders Inclusive internal process
Major Considerations in Physician Payment Disclosure Scope Content Systems issues Physician Review Timing Sequencing
Goals and Metrics Accuracy Timeliness Efficiency Responsiveness Education Maintaining Stakeholder Relationships Preserving Business Confidentiality Building Trust
A Look Ahead Expanding disclosures Implementing new laws Keeping the dialogue going