HFT Rules: Three Part HFT Harmony
The final regulations implementing the Physician Payments Sunshine Act take effect April 9, 2013. Pharmaceutical manufacturers, group purchasing organizations, academic medical centers and physicians need to be ready to...more
“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...more
Report Submission and Review Pre-Submission Review is Not Required Applicable manufacturers may voluntarily provide covered recipients the opportunity to review the data prior to submission to CMS, but doing so is not...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
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