The Centers for Medicare & Medicaid Services (CMS) issued updated guidance on the thresholds that Applicable Manufacturers and Group Purchasing Organizations are required to report annually under the Sunshine Act (42 U.S.C. §...more
On July 30, 2019, the Centers for Medicare & Medicaid Services ("CMS") announced more proposed changes to the Open Payments Program. The Open Payments reporting requirements, otherwise known as the Sunshine Act, require...more
A recent High Court decision concerning compliance with a data subject access request considered the basis upon which an individual can require the data controller to provide the names of those in receipt of his or her...more
A federal district court has amended its opinion and order that held in favor of cedent Munich Re on its breach of contract action against American National Insurance Company to add a covered insurance claim to the list of...more
On July 10, 2013, a majority of a three-judge panel of the Superior Court of Pennsylvania cut a new path for insureds and insurers with respect to defense under reservations of rights. See The Babcock & Wilcox Company, et al....more
On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) released a final rule implementing the Physician Payment Sunshine Act (the “Act”). The Act requires certain manufacturers of covered drugs, devices, and...more
The Final Rule implementing the Physician Payment Sunshine Act was announced on February 1st and published in the Federal Register on February 8th. The Final Rule establishes procedures for drug and device manufacturers to...more
On February 8, 2013, 16 months after the statutory deadline, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register the final regulation implementing the physician payment transparency...more
On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited final regulations implementing the Physician Payment Sunshine Act (Act or Sunshine Act). The Sunshine Act requires drug,...more
Reports on Physician Ownership and Investment Interests The Sunshine Act requires applicable manufacturers, as well as applicable GPOs, to report to the Secretary, in electronic form, certain information concerning...more
“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
Late afternoon on Friday February 1, 2013, the Centers for Medicare and Medicaid Services ("CMS") published the final rule regarding Transparency Reports and Reporting of Physician Ownership or Investment Interests ("Final...more
“Covered Recipients” - Physicians - The Final Rule retains the proposed definition of “physician” as meaning doctors of medicine and osteopathy, dentists, podiatrists, optometrists, and chiropractors, who are...more