Proposed Physician Payment Sunshine Act Regulations Leave Many in the Dark

Originally published in Health Care Fraud Report, 16 HFRA 80, 01/25/2012.

Pharmaceutical and medical device manufacturers as well as group purchasing organizations (GPOs) finally received some insight into how the Centers for Medicare & Medicaid Services intends to implement the Physician Payment Sunshine Act (Sunshine Act), which was enacted as part of the Patient Protection and Affordable Care Act. On Dec. 14, 2011, CMS published a Proposed Rule (Proposed Rule) that addresses certain crucial details but left many questions unanswered pending review of comments from manufacturers and other interested parties.

Of immediate importance is the postponement of the Jan. 1, 2012, start date for the collection of data by manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid, or the Children’s Health Insurance Program (Manufacturers) and by GPOs regarding payments or other transfers of value (including ownership and investment interests) given to physicians and teaching hospitals.

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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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