In a final rule published in the Federal Register on November 13, 2014, the Centers for Medicare and Medicaid Services (CMS) eliminated the federal Sunshine Act reporting exclusion for payments to physicians at continuing...more
On August 15, 2014, the Centers for Medicare and Medicaid Services (CMS) re-opened the Open Payments system for physicians and teaching hospitals to register, review, and, if needed, dispute information gathered to date. CMS...more
On August 7, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that the Open Payments system is “temporarily” off-line. The CMS announcement did not state when the Open Payments system would be back on-line....more
The Centers for Medicare and Medicaid Services (“CMS”) issued a proposed rule that includes a plan to eliminate the continuing medical education (“CME”) exclusion to the reporting requirements under the federal Physician...more
On April 9, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released the Medicare Provider Utilization and Payment Data: Physician and Other Supplier Public Use File (the “Data File”). The Data File contains...more
The Centers for Medicare & Medicaid Services (“CMS”) recently released guidance on its website describing a two-phase process for applicable manufacturers and group purchasing organizations (“GPOs”) to register and submit...more
In This Issue:
- Third Circuit Panel Liberalizes “Protected Activity” Immunity for Employees Claiming Whistleblower Status
- Doing Time: A Requirement for White Collar Crime?
- Casting a Smaller Net:...more
4/23/2013
/ Centers for Medicare & Medicaid Services (CMS) ,
Continuing Medical Education ,
Financial Conduct Authority (FCA) ,
Fraud ,
GPOs ,
Protected Activity ,
Publicly-Traded Companies ,
Sarbanes-Oxley ,
Settlement ,
Shareholders ,
Sunshine Act ,
Transparency ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The final regulations implementing the Physician Payments Sunshine Act take effect April 9, 2013. Pharmaceutical manufacturers, group purchasing organizations, academic medical centers and physicians need to be ready to...more
Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity.
...more