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HCP Consulting Agreement Fair Market Value Review

A fair market value review that checks each surgeon consulting invoice before it is paid: the need written first, the agreement, the rate inside its tier, and every billed hour against the record behind it.

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Follow one surgeon's quarterly invoice to payment ↓
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The problem

Rate and contract get checked, and the billed hours almost never do

A device maker pays surgeons to review designs, work in cadaver labs, read protocols and teach courses. The arrangement holds up only with a need written before the agreement, services named in writing, pay set in advance at fair market value, and proof the work was done.

Rate tools set the hourly rate and contract tools hold the agreement. Nobody rebuilds the hours on the invoice from the meeting system, the lab sign-in sheet or the course roster, so a design review that was canceled, or one the surgeon never joined, gets paid and then reported to the government as paid.

Built forCompliance officersHCP contracts managersProgram leadsInternal auditors

The Problem Today

Surgeon consulting invoices are paid on contract and rate; the hours are rarely checked against what happened.

20,000
invoices in a year for a big device maker our estimate
$3.92B
general payments to clinicians reported for one program year published

What an analyst checks by hand

  • Agreements
  • Rate tiers
  • Attendance
  • Work proof
  • Canceled meetings get paidAnd the same wrong amount is reported publicly
  • Need written after the factOr rates stretched past the tier experience supports

The Solution

  1. Need, terms and rate readNeeds assessment written first, agreement terms, rate inside its tier
  2. Each billed hour rebuiltFrom attendance, lab sign-in sheets, review sessions and course rosters
  3. A query, records attachedThe consultant corrects each line in fixed fields; then a fresh check
  4. Compliance signsAfter opening a stated sample; transparency records follow by nature

Built-in controls

  • Preparer, attester and approver are three people
  • Typed words never count as evidence of work
  • Nobody here grades a surgeon's clinical opinions

What You Get

Consultants are paid for work the records show, and each payment reaches the transparency report at the amount the records support.

  • A sample written downEach signer opens what is stated before signing
  • Annual limits that blockAn invoice over its limit stays out of the batch
  • Corrections checked againA corrected invoice starts from a fresh read
One invoice, one morning

A fair market value review of one surgeon's quarter: 38 hours claimed

An orthopedic surgeon consults on a knee instrument program at $500 an hour. Her quarterly invoice arrives with four kinds of work on it.

demoThe surgeon, the program, the company, the staff, the hours and the dollars are all sample data.

  1. 0109:00

    38.0 hours billed, and nothing on the invoice has been checked

    HCP contracts manager

    The invoice opens with each billed activity as a striped bar of hours claimed: design review meetings, a cadaver lab, protocol review and two training faculty days. The bars for what the records show are empty and every line says not read yet. Beside them sit the needs assessment, the rate and the agreement terms, also unread.

  2. 0209:01

    The need came first, and $500 sits inside the tier's $400 to $520

    HCP contracts manager

    He starts the read. First, the agreement reader confirms the signed agreement, its term and $500 an hour set in advance. The need checker finds the needs assessment approved before signing, four consultants needed and four engaged, with no sales input. The rate checker places her in tier 2 from 16 years in practice and fellowship training.

  3. 0309:03

    Design review: 12.0 hours claimed, 7.5 hours the records show

    HCP contracts manager

    Three lines match to the hour. The design review meetings do not: 8 meetings billed at 1.5 hours, 5 with attendance. One meeting was canceled two days ahead, and at two others she was invited and never joined. The agreement allows up to two meetings a month, and two months of the quarter were each billed three.

  4. 0409:06

    He opens each of the three meeting records before any query can go

    HCP contracts manager

    The query cannot be sent until the sender has read the records behind it. He opens the design review list: joined and left times for the five she attended, a cancellation entered by the program lead, and two meetings held with eight and nine attendees recorded, her name not among them. Claimed 12.0 h, records 7.5 h.

  5. 0509:07

    The query is approved wording, with the three records attached

    HCP contracts manager

    The query writer drafted it from wording compliance had already approved: the three dates, what each record shows, and a request to correct the lines or attach a record of attendance. He adds nothing, so compliance does not need to read a changed sentence first. He sends it, and payment is held until she answers.

  6. 0609:12

    In her own portal, she marks the three meetings billed in error

    Consulting surgeon

    The surgeon signs in to the consultant portal and sees the same letter. Each line takes hours to bill and one reason from a fixed list: billed in error, I took part, or the meeting moved. She picks billed in error three times and sets each to zero. There is no free-text box to argue in.

  7. 0709:15

    The corrected invoice is read fresh: 33.5 hours, each with its record

    HCP contracts manager

    A corrected invoice does not inherit the earlier pass. The agents read revision 1 again: only the design review lines changed, every hour now matches a record, the year reaches 97.0 of 120 hours, and the deliverables are still present and signed. The payment comes to $17,586.70 with travel, ready for him to prepare.

  8. 0809:22

    The program lead attests the work arrived, without grading her opinions

    Program lead

    After the contracts manager prepares it, the program lead opens the deliverables pack: the signed review memo, two lab evaluation forms and the course roster. He attests that the services were performed and the deliverables received. The content of her clinical opinions is not his to judge here, and the attestation says so.

  9. 0909:27

    Approved at $17,586.70 after opening the stated sample

    Compliance officer

    Her sample is written on the screen before she signs: the corrected invoice against its records, plus one line drawn at random with seed 4127, a course roster. She opens it, then approves with her own password. At 09:28 the transparency recorder drafts three records, split by nature of payment.

What the records support on one invoice, line by line

Hours times the agreement's rate, with travel checked against the policy.

Claimed: 38.0 hours at $500$19,000
Design review hours with no record4.5 h: one canceled meeting, two she never joined−$2,250
Hours the records support: 33.5$16,750
Travel for the cadaver lab: airfare, hotel, ground$836.70
Approved for payment$17,586.70
Hours this year with this invoice, of the 120-hour limit97.0 h

demoSample data, from the working solution.

Around the approval

Rate tiers, agreement terms and transparency records behind each payment

Where compliance, internal audit and the administrator look when a payment is questioned.

Transparency draftsConsulting fee $10,750.00, faculty $6,000.00 and travel $836.70, drafted only after approval. Compliance attests the filing.
Audit trailEach read, query, answer, signature and draft in order, with the session and the meaning the signer gave it.
The agreementTerms as written: signed date, term, services, rate set in advance, the annual limit and the needs assessment it rests on.
The customer's rate cardOpened from the invoice at its source: the three hourly tiers for orthopedic and spine surgeons, set by years in practice and training, with her tier marked.
Rules and limitsHours tolerance, batch sample, invoices always opened, the countersign threshold and the review clock. A compliance signer approves each change.

demoSample data, from the working solution.

Preparer, attester and approver are three different people

Nobody approves what they prepared or attested.

HCP contracts manager
Sees
Lines where hours and records differ
Signs
Sends queries and prepares each approval
Consulting surgeon
Sees
Her own invoice and the records behind each question
Signs
Answers line by line from fixed choices
Program lead
Sees
The deliverables pack
Signs
Attests the services were done, not their clinical content
Compliance officer
Sees
A sample stated before she signs
Signs
Approves the payment and attests the transparency filing
Chief compliance officer
Sees
Large batches and annual limit cases
Signs
Countersigns batches over the threshold
Seven agents before payment

They rebuild the hours and draft the query, and people decide the pay

Each one has a line it does not cross.

Agreement reader

Reads the agreement and statements of work: signature, term, services, pay method, annual limit.

  • Never judges legal sufficiency
Need checker

Finds the needs assessment and checks its date, consultant count and sales input.

  • Never decides a need is legitimate
Rate and cap checker

Places the consultant in a tier from years and training and adds the invoice to the year.

  • Never sets a rate
  • Never uses sales data
Hours rebuilder

Matches each billed hour to its record and checks travel receipts against the policy.

  • Never accepts typed text as evidence
Deliverable checker

Checks each deliverable exists, is signed and is dated in the period.

  • Never reads or grades clinical opinions
Query writer

Drafts the question from approved wording with the records attached.

  • Never sends
  • Never writes new wording
Transparency recorder

Drafts transparency records by nature of payment once a payment is approved.

  • Never drafts before approval
  • Never submits a filing

Fair market value itself, the need and the law stay with people

What fair market value isThe rate card is the customer's own method, signed by two compliance signers.
Whether a need is realThe program lead and compliance approve the needs assessment before any agreement is signed.
Legal judgmentThe screen shows the records against each standard; compliance and counsel decide what the law requires.
Clinical contentDeliverables are checked for being present, signed and dated, never for what they say.
Anything about a product problem or someone's healthNot read or answered here. The consultant portal has no box to type one into, and her screen names the complaint handling contact.

What compliance officers ask about fair market value review

What is a fair market value review of a consulting invoice?

A fair market value review checks that a consulting payment to a surgeon or other clinician rests on a need written in advance, a signed agreement, a rate set at fair market value, and proof the work was done. Here agents rebuild each billed hour from its record before compliance approves.

Does it set our fair market value rates?

No. It reads the rate card your compliance team approved and places each consultant in a tier from years in practice and training. Changing the card needs two compliance signers.

What records does it rebuild hours from?

Meeting attendance, lab sign-in and sign-out sheets, time-stamped review sessions and course faculty rosters, as each agreement names them. Typed notes and a consultant's own attachments do not count as evidence.

How does the consultant answer a query?

In a consultant portal, line by line, from fixed choices with hours to bill or a record to attach. The corrected invoice is then read again from the start.

When are the transparency records drafted?

Only after the payment is approved, split by nature of payment at the amount the records support. The compliance officer attests the filing; no agent submits it.

Who signs a large batch of matching invoices?

The compliance officer opens a random sample plus every invoice above a set size. Over the countersign threshold, the chief compliance officer signs as well.

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Bring one quarter of consulting invoices
and the agreements behind them.

We will rebuild every billed hour from your records and show which ones have nothing behind them.

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