Sunshine Act

News & Analysis as of

CMS Releases 2012 Physician Medicare Data: Five Takeaways

On April 9, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released the Medicare Provider Utilization and Payment Data: Physician and Other Supplier Public Use File (the “Data File”). The Data File contains...more

Overview of Primary Provisions of U.S. and French Sunshine Reporting Requirements

2013 was a year of unprecedented scrutiny of financial relationships between manufacturers and health care professionals, such as physicians. Both the United States and France imposed sweeping new reporting and disclosure...more

CMS Releases Physician Medicare Billing Data

The U.S. Department of Health and Human Services (HHS) announced on April 9th a “historic” release of Medicare payment data to provide consumers with “unprecedented transparency on the medical services physicians provide and...more

Registration and Data Submission Begin Pursuant to the Sunshine Act

The Centers for Medicare & Medicaid Services (“CMS”) recently released guidance on its website describing a two-phase process for applicable manufacturers and group purchasing organizations (“GPOs”) to register and submit...more

Open for Business: CMS Open Payments System Begins in Phases

With the Open Payments System rollout, came the phased approach for data submission, requiring aggregate data in Phase 1 and detailed data reporting in Phase 2. ...more

The Physician Payment Sunshine Act – The Top Five Steps for Physicians: The law defines “payment” to include almost any imaginable...

The Physician Payment Sunshine Act is a minor part of the Affordable Care Act, but it could result in major headaches for physicians. The chief purpose of the Sunshine Act is to make any payments made by medical manufacturers...more

CMS Announces Sunshine Act Open Payment Registration To Begin on February 18, 2014

On Friday, February 7, 2014, CMS announced that Open Payments registration is scheduled to begin on Tuesday, February 18, 2014 for applicable manufacturers and applicable group purchasing organizations (GPOs). ...more

CMS Releases Long-Awaited Details for Sunshine Act Compliance

The Physician Payment Sunshine Act (the "Act") was enacted as part of the Patient Protection and Affordable Care Act for the purpose of promoting transparency between the medical industry and health care providers. It...more

More Open Questions About Open Payments Under the Sunshine Act

Last week, the Centers for Medicare & Medicaid Services (“CMS”) clouded the process for pharmaceutical and medical device manufacturers, and group purchasing organizations (“GPOs”), to register and submit reports under the...more

Capital Thinking: Health Care

SGR Policy Framework Deal - Last week, the Chairmen and Ranking Members of the three committees of jurisdiction over Medicare (Senate Finance Committee, House Ways and Means and Energy and Commerce Committees) announced...more

CMS Issues New Policy on Disclosure of Physician Payment Information

On January 17, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that it will release Medicare expenditure data on specific physicians under the Freedom of Information Act (FOIA). This new “transparency”...more

FOIA Settlement Advances Story on Civil Rights-Era Informant Records

A unique settlement in a Washington, D.C., Freedom of Information Act lawsuit has provided a Memphis newspaper unprecedented access to the FBI's informant records from the civil rights era, including documentation of the U.S....more

New Tools to Comply with the Brown Act and Increase Transparency

Meeting management is big business for governments at every level, and the recent enactment of SB 751 has many public agencies reviewing the policies and tools they use to manage their public meetings. SB 751 requires...more

Land Wars in Asia: Battles – The Most Classic of Blunders

You have the products-liability case of a lifetime. The Complaint’s been filed. The Answer is in. Discovery time. You sit down and craft a discovery plan. Fine-tuned. Perfection. You sent it out and receive – blanket...more

Physician Groups Seek Sunshine Act Changes

Seventy-four state and federal physician organizations, including the American Medical Association, recently asked the Centers for Medicare & Medicaid Services (“CMS”) to exclude textbooks and peer-reviewed medical journal...more

French National Councils and Companies Publicly Disclose Information About Interactions with French Health Care Professionals for...

On October 1, 2013, seven national councils representing French health care professionals posted on their publicly accessible websites information submitted by affected enterprises (i.e., companies) that produce or market...more

Data Collection Under The Sunshine Act

Data collection requirements under the Physician Payment Sunshine Act commenced August 1, 2013. This provision of the Patient Protection and Affordable Care Act and the corresponding regulations require an entity that is...more

Health Care E-Note - September 19, 2013

In This Issue: - Many States Want More Oversight of Health Insurance Navigators - Insurers, Hospitals Argue Over Who Pays When Enrollees Default - ACA Increases Scrutiny of Doctors' Gifts, Payments - States...more

The Sunshine Act: Putting It into Practice – Interview with Karen Lovitch, Member, Mintz Levin [Video]

Attorney Karen Lovitch, Practice Leader of Mintz Levin's Health Law Practice, discusses the challenges facing pharmaceutical and medical device manufacturers in complying with the Sunshine Act....more

CMS Continues To Issue Guidance On Sunshine Act Reporting

Three weeks after the commencement of data collection under the Physician Payment Sunshine Act (the “Act”), the Centers for Medicare & Medicaid Services (“CMS”) continues to issue guidance to assist applicable manufacturers...more

CMS Confirms Classification of Physicians Abroad as 'Covered Recipients'

On August 8, the Centers for Medicare & Medicaid Services (CMS) confirmed its classification of physicians practicing medicine abroad but who maintain a current license in any U.S. state as “covered recipients” for purposes...more

Sunshine Act Data Collection Checklist

As we discussed in an earlier post, the data collection obligations under the Physician Payment Sunshine Act commenced on August 1, 2013, and all affected “applicable manufacturers” and group purchasing organizations should...more

Transparency Update: U.S. Sunshine Collection Obligations Take Effect

Many organizations continue to face challenges with the technology and integration of some of the more complex interpretations. On August 1, the U.S. Sunshine Act and its data collection obligations took effect....more

Ready or Not – Sunshine Act Data Collection Starts Today

Today pharmaceutical and medical device manufacturers and group purchasing organizations (“GPOs”) start to collect data on their financial arrangements with physicians and teaching hospitals to comply with the Physician...more

Client News Alert: Regarding Physician Payments Sunshine Act

On August 1, 2013 a new reporting obligation under the federal Physician Payments Sunshine Act (“Sunshine Act”) takes effect. The Sunshine Act was originally signed into law on March 23, 2010, as part of the Patient...more

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