Sunshine Act

News & Analysis as of

EEOC to Hold Meeting April 15 at Miami Dade College

EEOC at 50: Confronting Racial and Ethnic Discrimination in the 21st Century Workplace - WASHINGTON -- The U.S. Equal Employment Opportunity Commission (EEOC) will hold a meeting on Wednesday, April 15, at 9:00 a.m....more

Open Payments/Sunshine Act Year Two: Guidance for Physicians

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

French Supreme Administrative Court decision significantly broadens scope of the French ‘Sunshine Act’

On 24 February 2015, the French Supreme Administrative Court (Conseil d’Etat) reached a landmark decision which significantly expands the scope of the so-called French Sunshine Act....more

Blog: CMS Issues Additional Sunshine FAQs

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

French Supreme Court Specifies Requirements for Health Care Companies Under the Sunshine Act

Law no. 2011-2012 of 29 December 2011, also known as the French Sunshine Act, introduced into French law disclosure obligations imposed on health care companies (HCC). The French Medical Board and a nonprofit organisation...more

Florida Appellate Court: Open Meetings Law Applies to Collective Bargaining

In a crucial victory for transparency, a Florida state appeals court ruled that the state's open meetings law will not "condone hiding behind federal mediation" when municipal governments try "to thwart the requirements of...more

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

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

EEOC to Probe Harassment at Jan. 14 Meeting

WASHINGTON -- The U.S. Equal Employment Opportunity Commission (EEOC) will hold a meeting on Wed., Jan. 14, at 9:30 a.m. (Eastern Time), at agency headquarters, 131 M Street, N.E., Washington D.C. In accordance with the...more

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

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

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

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

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

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

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

More Disclosure Needed as SEC Sunlight Shines

The US Securities and Exchange Commission's (SEC) “Spreading Sunshine” speech in early May 2014 heralded a new era of disclosure for private equity firms. Under the spotlight were fees, allocation of expenses, co-investment,...more

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

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

CME Payments Exposed to Sunshine, But Not Too Much

Sometimes there’s less to life than meets the eye. Take the final rule issued last Friday by CMS on reporting CME (for continuing medical education) payments under the Physician Payments Sunshine Act....more

Blog: CMS Exempts CME and Makes Other Sunshine Reporting Changes

Late last week, the Centers for Medicare and Medicaid Services (CMS) issued the 2015 physician payment fee schedule, which includes changes to the Final Rule implementing the federal Sunshine law. ...more

CME Payments Largely Remain Excluded From Sunshine Act Reporting

The Centers for Medicare & Medicaid Services (“CMS”) has finalized changes to a number of reporting requirements under the regulations implementing the Physician Payments Sunshine Act (“Final Rule”). When CMS proposed...more

CMS Announces Plan for Reporting Returned Sunshine Act Payment Data

On October 30, 2014, the Centers for Medicare and Medicaid Services (“CMS”) announced the procedure for applicable manufacturers and group purchasing organizations (“GPOs”) to report payment and ownership information that was...more

Surge in FOIA Requests to State Agencies Seeking Information About PE and Other Alternative Investment Fund Sponsors

We have recently observed a surge in freedom-of-information (“FOIA”) requests made by media outlets to state pension funds and other state-government-affiliated investment entities. Although the requests have so far...more

Florida Appellate Court: Open Meeting Law Applies to Collective Bargaining - The Florida Court Holds That a Mediation Settlement...

In a crucial victory for transparency, a Florida state appeals court ruled on Oct. 21, 2014, that the law will not "condone hiding behind federal mediation" when municipal governments try "to thwart the requirements of the...more

CMS Publishes Open Payments Data Detailing Payments and Transfers of Value Provided by Life Sciences Manufacturers to Physicians...

On September 30, 2014, CMS published data regarding payments and transfers of value that pharmaceutical, biologic, and medical device manufacturers provided to U.S. physicians and teaching hospitals during the period August 1...more

Sunshine Act Update: First Data Set Published

On September 30, the Center for Medicare & Medicaid Services (CMS) published the first set of data reported by pharmaceutical, medical device, biotechnology and medical supply companies, and group purchasing organizations...more

Blog: Sunshine Act Media Coverage and CMS’s Response Today

The Open Payments database has been live for a week now. There has been media coverage, but most has not been the type that many expected. The coverage to date has largely centered on the significant challenges associated...more

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