Collect NPI Numbers and avoid Sunshine Act Fines
Pharma and Medical Device manufacturers:if you exhibit at trade shows where the attendees are physicians and other HCP’s, you can’t give them anything worth more than $10 unless you collect their NPI number and report it to the government in a very specific format. If you don’t, your company can be fined from $1,000 to $10,000 per incident, more than $1 MM per year. It’s part of the Sunshine Act that seeks to make sure doctors are not unduly influenced in their buying or purchasing decisions.
If you have an espresso bar, crepes in your booth or perhaps you host a free seminar with a box lunch, you must report. If you did not collect the NPI numbers of the HCP’s and report this “Transfer of Value” (ToV), you could be fined between $1,000 and $10,000 for reach HCP that you failed to report. (It’s $1,000 if it was a simple mistake or oversight; it’s $10,000 per HCP if you knew you could have done it but decided not to).
What is Required by Law
Anything valued at $10 or more that you give to a Health Care Professional (HCP) who is an MD, DO, PA, NP, Dentist, Orthodontist, Podiatrist,Chiropractor or Optometrist must be reported as a Transfer of Value (ToV). The exception to rule is if the food is given to everyone at the congress regardless of who they are and only IF the participants are not easily identifiable (if they don’t have a name badge with MD or a bar code you could scan). The definition of this is vague; why take a chance on the government’s interpretation after they decide to fine you?
CMS requires the following data about the recipient of the ToV: NPI number, practice address as it appears in the NPPES database (home address is not acceptable), state and license number (in all states in which the HCP is licensed), taxonomy number and designation. In addition to the HCP specific information,, CMS also requires the item and type, value and several other data points, some of which are derived fields. That’s a lot of information to collect for Uncle Sam and it’s especially difficult at a trade show to find the mysterious NPI number.
What’s an NPI Number?
The NPI is the National Provider Identifier, a unique ten-digit number that every US doctor is assigned. Many sales databases and office call lists include these numbers because they are the only permanent unique identifier for an HCP, No matter how may moves a doctor makes in their early career, the NPI number sticks with them forever.
Why is is hard to find an NPI number at a medical meeting, congress or trade show?
When doctors register for events, many times they will use their home address because it is the one place they know they can get their mail. After all, they may work at a hospital, a clinic and have a private practice, so a home address is the best choice. So matching a home address to an NPI number is nearly impossible because the CMS database does not contain home addresses. Other required data not found on the badge includes the HCP’s specialty (Taxonomy code), their state license number(s) and business address as listed in the NPPES (government) database.
Problems with after-event NPI matching
Matching up this data after a trade show or medical congress is a very manual process and often yields very poor results. First, your team must have an accurate and current copy of the NPI database with all of the additional information inserted. Even experienced IT teams have fewer than 20% match success after a show. Home addresses, maiden names, outdated addresses, common last names other factors make post-event matching highly inaccurate and incomplete.
Matching Data On-Site in Real-Time
The fastest and most accurate was to find NPI numbers and the rest of the required data is to scan badges and find matches on-site, in real time. The NewLeads NPI Match system uses a proprietary database containing current NPPES (CMS) data on every HCP in the USA. Using filters, organization and data optimization, the NewLeads system matches a doctor’s home address with their practice address (that may be up to 60 miles away) in less than a second–even if it is another state (e.g. NJ to NY). Once the match is made, all of the required government data is retrieved from our database, including the NPI #, the state and license number(s), taxonomy code and designation). Here’s an example of a physician’s badge scan and how our match works on an iPad. The google map was added to provide a visual of where we found the HCP’s practice: