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Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Applicable Manufacturers

“Applicable Manufacturers” - Common Ownership Considered to be Ownership by the Same Individuals or Entities of 5 Percent or More in Two Entities - In the Final Rule, CMS defines “applicable manufacturer” as an...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Report Submission and Review

Report Submission and Review Pre-Submission Review is Not Required Applicable manufacturers may voluntarily provide covered recipients the opportunity to review the data prior to submission to CMS, but doing so is not...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Payments or Other Transfers of...

“Payments or Other Transfers of Value” Payments or Other Transfer of Value Must Have a Discernible Economic Value.In the Final Rule, CMS interprets value as the discernible economic value on the open market in the United...more

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