Teaching Hospitals and Physicians Must Take Action Now to Correct Erroneous Reports about them Submitted Under the Sunshine Act


On September 1, 2014, the Centers for Medicare and Medicaid Services (CMS) will make public the reports submitted by pharmaceutical and medical device manufacturers under the Sunshine Act.  These reports will disclose payments and other "transfers of value" by pharmaceutical and medical device manufacturers to teaching hospitals and physicians.  It is predictable that for any number of reasons -- including human error, erroneous data, mistaken regulatory interpretations -- the reports will contain errors. 

Teaching hospitals and physicians wishing to ensure that reports that mention them do not contain erroneous information should register ASAP with CMS to review the reports before they are made public.  CMS is giving teaching hospitals and physicians until August 27 to resolve any issues with pharmaceutical and medical device manufacturers, and have manufacturers correct errors in their reports.  Erroneous information not corrected by August 27 will be included in the reports made available to the public on September 1.

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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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