Healthcare and life sciences companies rely on input from thought leaders (e.g., physicians or other healthcare professionals (HCPs)) to provide advice on various topics such as product development or research, to serve as peer-to-peer educators, to oversee clinical trials, or to serve as a moderator or attendee at conferences or other events.  Companies often provide payment, reimbursement of expenses, or other things of value to these individual(s).   

To minimize scrutiny and to ensure the legitimacy of these transactions (and to technically fall under “safe harbor” provisions of the US Anti-Kickback statute), the individual must be paid what is referred to as a “Fair Market Value” (FMV) rate for these types of engagements. FMV can be challenging to determine, and many companies rely on external vendors or consultants to provide what are referred to as FMV “rate cards”, which provide a single rate or range of rates for HCPs based on geography, specialty, level of expertise and/or experience. 

If a Service Fee will be provided to an HCP, FMV fields within your request must be filled in. 

First you will need to submit a new FMV profile request to add the FMV rate into Master Data. 

• After your FMV rate is added in Master Data you can add your recipient to your request. 
• If you already added the recipient to your request prior to updating Master Data, you must follow the instructions below.

For recipients in Draft status:

Delete the recipient with the old FMV rate. 

Readd the recipient to the request.

For recipients in In Progress status:

Cancel the recipient with the old FMV rate. 

Readd the recipient to the request. 

Submit the recipient that you readded for approval. 

If a HCP's FMV rate has changed within Master Data and a submitter needs to update their Draft or In Progress request to reflect the new amount, please follow the steps below. 

For recipients in Draft status:

Delete the recipient with the old FMV rate. 

Readd the recipient to the request.

For recipients in In Progress status:

Cancel the recipient with the old FMV rate. 

Readd the recipient to the request. 

Submit the recipient that you readded for approval.