Transparency Consultation Update: Insights into Italy’s Telematic Register

We’re excited to share the latest developments regarding the Transparency Consultation that concluded on September 24, 2023. This consultation was eagerly anticipated by industry leaders seeking further guidance on the intricacies of the telematic register and hoping for clarification of ambiguities within the Draft Decree and the text of the law.

However, the recently released Final Report of the Transparent Healthcare Consultation could have offered the expected level of detail. Instead, it provided a comprehensive overview of the quantitative and qualitative contributions received through the questionnaire.

We remain optimistic that the Ministry of Health will soon provide more comprehensive details and guidance. Given the expectation that the telematic register will go live by the end of 2023, with the first set of data to be disclosed by July 1, 2024, further information is highly anticipated.

The Draft Decree, as part of this consultation, reviewed the required data elements, indicating which points will be included in the publications. It also offered concise descriptions of each data point. The technical specification, on the other hand, defined the structure and technical characteristics of the electronic public register, along with the requirements and methods for disclosing TOV data onto the register.

The register itself is organized into three distinct sections:

Section A: Data related to disbursements, conventions, and agreements benefiting entities in the health sector and healthcare organizations.
Section B: Data regarding shares, capital shares, bonds, and proceeds derived from industrial or intellectual property rights, benefiting entities in the health sector and healthcare organizations.
Section C: Data pertaining to acts of imposing sanctions.

The technical specification outlines a comprehensive set of data entry points, including details such as an HCP’s date of birth, place of birth, and qualifications, all of which are required for disclosure on the telematic register, even if they won’t be made public. This transparency initiative is a significant step toward ensuring the integrity of Italy’s healthcare system. Stay tuned for further updates as we continue to navigate this evolving landscape.

For an in-depth study of the data entry points, please visit THE LAW section of the website and download the ‘Draft Decree Document’.