Sunshine Act

White Collar Watch - April 2013

by Bruce D. Armon, Andrea P. Brockway, Michael Finio, Christopher R. Hall, Keith Lorenze, Nicholas J. Nastasi, Courtney L. Schultz, Brian Simons | Saul Ewing LLP on 4/23/2013

In This Issue: - Third Circuit Panel Liberalizes “Protected Activity” Immunity for Employees Claiming Whistleblower Status - Doing Time: A Requirement for White Collar Crime? - Casting a Smaller Net:...more

CMS Creates "Open Payments" Website For Reporting Under The Physician Payment Sunshine Act

by Thomas Donohoe, Lauren Groebe, Lindsay Kessler, Matthew Murer | Polsinelli on 4/18/2013

On April 12, 2013, the Center for Medicare and Medicaid Services (“CMS”) created the “Open Payments” website where reported information under Section 6002 of the Affordable Care Act (“ACA”), commonly referred to as the...more

Health Reform + Related Health Policy News Update - April 2013

by Jane Arnold, Anika Clifton, Thomas Donohoe, Colleen M. Faddick, Matthew Murer, Alan K. Parver, Emily Wey | Polsinelli on 4/17/2013

In this Issue: - Top News ..Large Hospital Systems Settles for $25.5 Million for False Claims Act Allegations ..Catholics’ Challenge to Contraceptive Coverage Mandate Dismissed As Not Ripe - States...more

CMS Officially Launches National Physician Payment Transparency Program Website

by Karen S. Lovitch, Kate Stewart | Mintz Levin - Health Law on 4/16/2013

The Centers for Medicare & Medicaid Services (“CMS”) recently launched the National Physician Payment Transparency Program: OPEN PAYMENTS website, which provides Sunshine Act compliance resources, including Fact Sheets and...more

Highlighting Transparency Through The Federal Sunshine Act Regulations

by Bruce D. Armon | Saul Ewing LLP on 4/9/2013

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

Physician-Owned Device Companies: OIG Issues Further Guidance

by Anthony Ten Haagen | Holland & Knight LLP on 3/29/2013

The Office of the Inspector General for the United States Department of Health and Human Services (OIG) issued a Special Fraud Alert on March 26, 2013 (the "2013 POD alert"), that identifies physician-owned distributorships...more

Hospitals and Doctors Beware: OIG Issues Special Fraud Alert on Physician-Owned Entities

by Kathleen McDermott | Morgan Lewis on 3/28/2013

Alert notes attributes and practices that produce substantial fraud and abuse risk. On March 26, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued its "Special Fraud...more

OIG Places Fraud and Abuse Spotlight on Physician-Owned Entities

by Bruce D. Armon | Saul Ewing LLP on 3/28/2013

Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity. ...more

OIG Issues Special Fraud Alert on Physician-Owned Distributorships (PODs)

by Ropes & Gray LLP on 3/28/2013

On March 26, 2013, the Office of the Inspector General (“OIG”) of the Department of Health and Human Services issued its first Special Fraud Alert in three years. The new Alert focuses on physician-owned distributorships...more

Getting Ready For The Physician Payment ‘Sunshine’ Rule

by Kathleen Howard, Joel R. Levin, Charles Mulaney, Jerica L. Peters | Perkins Coie on 3/22/2013

Originally Published in BNA Bloomberg, Medical Devices Law & Industry Report on March 20, 2013. On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited final regulations for...more

Here Comes the Sun: What You Need to Know about the Sunshine Act and Its Implementing Rules

by Edward Buthusiem, Cheray Lynch Sieminski | Berkeley Research Group, LLC on 3/20/2013

After years of deliberation, the Center for Medicare & Medicaid Services (CMS) published its long-awaited regulations to implement the specific requirements of the Physician Payment Sunshine Act (Sunshine) on February 1,...more

ProPublica's "Dollars for Docs": Will The Physician Payments Sunshine Provisions Clear The Haze?

by Robert Radick | Morvillo Abramowitz Grand Iason & Anello P.C.... on 3/20/2013

On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-delayed final rule that is intended to implement the Physician Payments Sunshine provisions that were included in the Patient...more

CMS Issues Rules On Physician Payments Sunshine Act

by Michael Volkov on 3/15/2013

People like to think they have it the hardest in life. I call it the competition among victims. If you are in the healthcare industry and fall under the Physician Payments regulations, then I think you are on your way to...more

Final Sunshine Act Arrives: Now the Hard Part

by Michele L. Buenafe, Jonathan Havens, Kathleen McDermott, Rebecca Osowski, Albert Shay | Morgan Lewis on 3/8/2013

The Centers for Medicare and Medicaid Services (CMS) issued the final regulations on the U.S. Sunshine Act on February 8, 2013. Transparency Reports and Reporting of Physician Ownership or Investment Interests, 78 Fed. Reg....more

CMS Publishes Final Sunshine Act Rule Creating New Regulatory Landscape for Physician-Manufacturer Interactions

by Tom Crane, Brian P. Dunphy, Kimberly J. Gold, Karen S. Lovitch, Kate Stewart | Mintz Levin - Health Law on 3/7/2013

Originally published in the Health Care Fraud Report, 17 HFRA 219, on 03/06/2013. The final rule (the ‘‘Final Rule’’) implementing the Physician Payments Sunshine Act (‘‘Sunshine Act’’), published in the Federal...more

Physician Payment Sunshine Act Final Rule Released

by Thomas Donohoe, Lauren Groebe, Lindsay Kessler, Matthew Murer | Polsinelli on 3/7/2013

In This Issue: - Interpretation and Clarification of Key Definitions ..Applicable Manufacturers ..Applicable GPOs ..Covered Drug, Device, Biological or Medical Supply ..Covered Recipients ...more

The Sunshine Physician Payment Final Rule Overview and Analysis

by Nancy Bonifant, Elizabeth Carder-Thompson, Katie Pawlitz | Reed Smith on 3/6/2013

On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) of the Department of Health and Human Services (HHS) released the long-awaited Final Rule (Rule) to implement the “Sunshine” provisions of the Affordable...more

Research-Related Payments and the Physician Payment Sunshine Act: How Reporting Works and What Applicable Manufacturers Should...

by Frederick Ball, Elinor Hart, Michael A. Swit | Duane Morris LLP on 3/6/2013

On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) published long-awaited rules (the "Rules") detailing manufacturers' and group purchasing organizations' reporting requirements under Section 6002 of the...more

Pro Te Solutio - Vol. 5 No. 4 November 2012

by Butler, Snow, O'Mara, Stevens and Cannada,... on 3/4/2013

In This Issue: - Forecast for the Physician Payments Sunshine Act: Partly Cloudy - Document Preservation Notices and the Lists of Who Receive Them: Are They Discoverable? - FDA Warning Letters Through...more

CMS Publishes Physician Payment Sunshine Rules; Manufacturers and Group Purchasing Organizations Are Required to Submit Detailed...

by Frederick Ball, Elinor Hart | Duane Morris LLP on 2/25/2013

On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited rules (the "Rules") detailing manufacturers' and group purchasing organizations' reporting requirements under Section 6002...more

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