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 entity operating in the United States that is (1)engaged in the production, preparation, propagation, compounding, or conversion of a covered drug, device, biological, or medical supply for sale or distribution in the United States, or in a territory, possession, or commonwealth of the United States; or (2) under common ownership with an entity in the first paragraph of this definition, and which provides assistance or support to such entity with respect to the production, preparation, propagation, compounding, conversion, marketing, promotion, sale, or distribution of a covered drug, device, biological, or medical supply. The Final Rule defines "common ownership" as when the same individual, individuals, entity, or entities, directly or indirectly, own 5 percent or more total ownership of two entities (such as parent, brother/sister, and subsidiary relationships).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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