State Reports - Categorizing Staff – MMIS

Question -

How are staff categorized on MA, VT, and DC state reports?

Answer -

MA and VT categorize staff in a similar way. however DC is a bit different. The descriptions of each can be found below:

Vermont

- requires reporting of “an officer, employee, agent or contractor of a person authorized by law to prescribe and practicing in Vermont…including nursing and front office staff.” Gifts, however, including lunch and learns are prohibited in Vermont.

To the extent a permitted expense is made to office staff, Vermont requires “the allowable expenditures made to the individual (including front office staff) must be allocated to a covered recipient.” Therefore if a payment is made to an HCP and their office staff member, the total is reportable to the HCP.

Massachusetts

- requires the same allocation. They provide an example in the FAQ guidance below.

Scenario: A modest lunch is provided in a physician’s office in conjunction with an informational presentation by a PMDMC sales representative, 5 MDs, 1 Office Staff, 1 Sales Representative, 7 Total attendees with a $315 dollar total bill.

What is the correct allocation and thus what is reportable for this event?

The $315 total cost would be divided equally among the 7 attendees. Each health care practitioner in attendance would receive a benefit of $45.00, which is below the $50.00 per transaction reporting threshold. Thus, no disclosure would be required of the PMDMC in this instance. Note:if the cost per participant exceeded the $50 threshold for reporting, the payment on behalf of the office staff member would have to be attributed to an identifiable covered recipient.

D.C.

States that office staff should be reported separately using the “other” recipient type in their gift expenses disclosure template.

In the most recent summary provided by D.C. for 2015, gifts to “Other Recipients” totaled $40,533. D.C. specified that this group includes individuals reported as Medical Staff, Front Desk, Billing Specialist, Office Manager, and Other. The majority of reported gifts were for Food and Beverage with $32,072 (79%) spent on 417 gifts (91.8%). The majority of payments took the form of In-Kind Items and Services with 388 payments (85.5%) totaling $34,701 (85.5%).