The Connecticut Department of Consumer Protection recently published a new expenditure disclosure form for reporting APRN payments on their website.
There has been much speculation regarding the specific requirements of the reporting obligations for the state. Polaris has noted that several companies have been incorrectly stating the reporting requirements, such as covered recipients, reporting period, reporting format and the deadline.
Per the provisions of Section 75 of Public Act 14-217, Connecticut requires reporting of payments by the manufacturers of covered drugs, devices, biologicals, or medical supplies to independently practicing advanced practice registered nurses. Previously, the state required the payment data submission to be done online via a Google Docs page. The new disclosure form, however, is in an excel format, and the first report must be submitted via email by July 1, 2017 to the Connecticut Department of Consumer Protection.
Manufacturers are required to submit the following information collected from January 1, 2016 to December 31, 2016: first and last name of the APRN, APRN’s CT license number, reporting time period, manufacturer name, manufacturer’s representative name, email and phone number, as well as the total value of payment to the APRN. Following the first report deadline (July 1, 2017), the second report will be due on July 1, 2018 for the payments data collected between January 1, 2017 and December 31, 2017.
Each manufacturer must aggregate the total payment amounts for each APRN, and declare that information in a single line entry for each APRN in the spreadsheet. It should be noted that Connecticut does not have a minimum threshold for reporting, so any payment or other transfers of value made to APRNs should be reported unless it meets the requirements for exclusion.
To help manufacturers identify the reportable APRNs, Connecticut published a current list of independently practicing APRNs. This roster includes Connecticut APRNs who are authorized to practice independently, and constitutes the pool of reportable APRNs.