News & Analysis as of

Centers for Medicare & Medicaid Services Sunshine Act

CMS Open Payments: A Look Behind the Curtain

by McGuireWoods LLP on

Compliance officers often lament that it is impossible to identify, assess and manage the compliance risks of financial relationships they know nothing about. Too often they are limited to relationships brought to their...more

MedPAC Takes Anti-POD Stance in Report to Congress, Echoing an Increasingly Uniform Consensus

by Ropes & Gray LLP on

On June 15, 2017, the Medicare Payment Advisory Commission (MedPAC), a non-partisan group that advises Congress on Medicare policy, released its annual Report to the Congress on Medicare and the Health Care Delivery System...more

Health Care Provider Insights - Introductory Edition

by Wilson Elser on

Welcome to the introductory edition of Health Care Provider Insights. We are practice management consultants, providing legal and business management advice and assistance to physicians and dentists (health care...more

Disputing Inaccurate Reports Under the Physician Payment Sunshine Act

by Ruder Ware on

The Affordable Care Act added the Physician Payment Sunshine Act (Sunshine Act) as section 1128G to the Social Security Act. The Sunshine Act requires applicable manufacturers of drugs, devices, biologicals, or medical...more

House Passes 21st Century Cures Act

by King & Spalding on

On November 30, 2016, the House of Representatives passed the 21st Century Cures Act, a bill intended to modernize health care delivery and speed up and improve medical research and innovations by removing bureaucratic...more

CMS Hosts Call on Potential Future Changes to Open Payments/Sunshine Act Reporting Requirements (Aug. 2)

by Reed Smith on

On August 2, 2016, CMS is hosting a Special Open Door Forum Call on potential future changes to Open Payments/Physician Payments Sunshine Act requirements for reporting payments and transfers of value made by drug and device...more

Delay in Final Rule Implementing PAMA: Sunshine Act Revisited?

As reported in our 2015 Laboratory Industry Year in Review post, the laboratory industry began 2016 amid confusion regarding how to comply with the Protecting Access to Medicare Act of 2014 (PAMA), which made the most...more

CMS Call on Opportunity to Review Open Payments/Sunshine Act Data (April 12)

by Reed Smith on

CMS is hosting a provider call on April 12, 2016 to discuss the Open Payments program, including the process for physicians and teaching hospitals to review applicable data on payments or transfers of value prior to...more

OIG Reviews Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors (PODs) of Spinal Devices

by Reed Smith on

The Office of Inspector General (OIG) of the Department of Health and Human Services has issued a report on “Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors.” The OIG reviewed 12 hospitals that...more

Open Payments Update: End of CME Exception for Sunshine Reporting

by Baker Ober Health Law on

On July 17, 2015, CMS announced updates to the Law and Policy page on the Open Payments website to provide additional guidance regarding the termination of the continuing medical education (CME) exception for reporting under...more

Blog: CMS Announces Updated Guidance Related to CME Reporting and Issues New Sunshine FAQs

by Cooley LLP on

Last week, the Centers for Medicare & Medicaid Services (CMS) announced that it updated its Open Payments Law and Policy webpage and issued 3 frequently asked questions (FAQs) related to the reporting of payments and...more

2014 CMS Open Payments Data Released

by Saul Ewing LLP on

On June 29, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published detailed information regarding payments made by pharmaceutical and medical device manufacturers to physicians and teaching hospitals during 2014...more

21st Century Cures Bill Includes Proposal to Broaden Sunshine Act Exclusions Related to Education

by Reed Smith on

As we reported last week, on May 21, 2015, the House Energy and Commerce Committee approved H.R. 6, the “21st Century Cures Act,” by a bipartisan, unanimous 51-0 vote. This major legislation is intended to accelerate the pace...more

Medicare Part D Data Release Continues Transparency Trend

The Centers for Medicare & Medicaid Services (CMS) recently added to the trend toward greater health care data transparency by releasing data about the prescription drugs that physicians and other health care providers...more

Blog: CMS’ Annual Open Payments Report to Congress Highlights Some Key Areas to Watch

by Cooley LLP on

The Centers for Medicare & Medicaid Services (CMS) must submit an annual report to Congress in connection with the federal Sunshine law. ...more

Open Payments/Sunshine Act Year Two: Guidance for Physicians

by LeClairRyan on

On June 30, 2015, the Centers for Medicare and Medicaid Services (CMS) will publish the first full-year report of payments to physicians from pharmaceutical and medical device manufacturers. Physicians who want to review...more

Blog: CMS Issues Additional Sunshine FAQs

by Cooley LLP on

The Centers for Medicare & Medicaid Services (CMS) released this week 5 new frequently asked questions (FAQs) related to reporting payments and transfers of value provided by applicable manufacturers and group purchasing...more

Blog: CMS Releases New Video Tutorial for 2014 Sunshine Reporting; Q&A Session Next Week

by Cooley LLP on

The Centers for Medicare and Medicaid Services (CMS) released today a 20 minute on-demand video tutorial related to the 2014 Open Payments reporting program. The video provides an overview of the registration, reporting and...more

CMS Issues Additional Sunshine Act Guidance With Respect to Payments to Speakers at Continuing Medical Education Events

by Saul Ewing LLP on

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

Sunshine Act Update: CMS Streamlines Reporting for CME-Related Payments in 2016

by Morgan Lewis on

CMS issues a Final Rule that removes the exclusion for reporting of continuing education payments to certain accredited organizations, while also clarifying previously existing parameters that may preclude reporting of these...more

Health Law Pulse - November 2014

by Robinson & Cole LLP on

In This Issue: - Connecticut Supreme Court: HIPAA Does Not Preempt Negligence Claims - CMS Removes Continuing Education Exemption to Physician Payments Sunshine Act - Federal Government and New York...more

CMS Changes Sunshine Rules for CME, Revises List of Data Elements to be Reported

by Stinson Leonard Street on

The Centers for Medicare & Medicaid Services (CMS) published a final rule with comment period addressing, among other issues, changes to the reporting and data collection requirements imposed upon “applicable manufacturers”...more

CMS Will Refresh Sunshine Act Data by December 31, 2014

by King & Spalding on

During the 15th Annual Pharmaceutical Compliance Congress and Best Practices Forum on November 4, 2014, Douglas Brown, Deputy Director of the Data Sharing & Partnership Group within CMS’s Center for Program Integrity,...more

CMS Finalizes Proposal to Remove Continuing Medical Education Exclusion from Sunshine Act Regulations

by McDermott Will & Emery on

On October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) issued its final Medicare physician fee schedule rule for CY 2015 (the Final Rule), which also includes certain changes to the Sunshine Regulations. ...more

Rules for CME, Revises List of Data Elements to be Reported

by Stinson Leonard Street on

Last Friday, the Centers for Medicare & Medicaid Services (CMS) published a final rule with comment period addressing, among other issues, changes to the reporting and data collection requirements imposed upon “applicable...more

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