Risk management guide for life sciences companies
Case Study

Streamlining FMV compliance: Automating KOL tiering in pharma consulting

Learn how Baker Tilly helped a top global pharmaceutical company determine key opinion leader (KOL) tiers across different regions in which they operate using a novel automated tiering database.
Risk management guide for life sciences companies
Case Study

Streamlining FMV compliance: Automating KOL tiering in pharma consulting

Learn how Baker Tilly helped a top global pharmaceutical company determine key opinion leader (KOL) tiers across different regions in which they operate using a novel automated tiering database.

Client background  

A top 25 global pharmaceutical company that operates in almost every region in the world.   

 The business challenge  

To comply with anti-kickback and anti-bribery regulations, life sciences companies must determine accurate fair market value (FMV) rates when engaging with KOLs for consulting activities. It is also essential to establish objective evaluation criteria to measure a physician’s expertise while recognizing that higher levels of experience typically command higher compensation. To do so, life sciences companies typically leverage levels, or tiers, of expertise to determine an appropriate hourly FMV rate. 

Since the company operates in different markets across the globe, the organization engages with a high number of healthcare professionals (HCPs) and non-HCPs in a variety of different settings. Each of those HCPs and non-HCPs must be tiered to determine their level of expertise and, subsequently, their FMV rate.  This presented a challenge for the company due to the high volume of HCP and non-HCP interactions resulting in a time consuming, resource intensive tiering process at risk for bias and human error. 

Baker Tilly’s solution-driven approach    

The company engaged with Baker Tilly to implement our novel automated tiering database, kolNOW®, for direct access to an on-demand, self-service application that provides pre-tiered KOLs based on objective, defensible, consistently applied criteria. 

Baker Tilly performed a thorough tiering comparison of the company’s 2023 KOL population in order to establish change management recommendations and decision points regarding tiering and FMV rates including: 

  • Tiering and FMV rate comparison for company selected KOLs 
  • Tiering comparison of random sampling of 35% of global KOLs 
  • Coverage analysis of 100% of KOLs 

The accomplished results   

Overall, >70% of the company’s KOL population were present in the global kolNOW database. 

Our tiering and FMV rate comparison analysis of company selected KOLs indicated 74% of the population showed an increase in their hourly compensation rate utilizing Baker Tilly FMV rates and tiers. 

In addition, 72% of the KOLs included in the random sampling comparison were tiered at a higher tier or had no change to their tier level assignment. Baker Tilly observed an initial decrease in tier level assignment for 28% of KOLs. 

After thorough review of each KOL that presented an initial lower tier level, Baker Tilly identified that the decreases in tier level assignment were primarily due to increased objectivity in tier and specialty assignments using kolNOW. We also identified specific examples of incorrect specialty assignments, outdated tiering evaluations, and subjective tier assignments lacking supporting documentation.  

In addition to providing access to kolNOW, Baker Tilly provided detailed change management recommendations and supporting materials for those KOLs whose FMV rates decreased as a result of down tiering or specialty change. 

For more information on this topic or to learn more about our compliance and ethics solutions for life science companies, connect with us today.  

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