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

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

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

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

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

The Countdown Begins – Sunshine Act Data Collection

With the August 1 deadline for data collection under the Physician Payments Sunshine Act (the “Act”) looming, CMS recently released two mobile applications (“Apps”) to help physicians and industry track payments and transfers...more

Let The Sunshine In – The Risks To Pharmaceutical And Medical Device Companies From Open Payment Transparency

Pharmaceutical and medical device manufacturers (as well as group purchasing organizations “GPOs”) have a major compliance challenge ahead — the Physician Payment Sunshine Act regulations. ...more

Sunshine Act Requires Reporting All Payments to Physicians

Beginning August 1, 2013, manufacturers of Medicare or Medicaid covered drugs, medical devices, biologicals and medical supplies must collect and make publicly available data on physicians and teaching hospitals with whom the...more

The Physician Payment Sunshine Act Final Rule: Key Change From Proposed Rule Affecting Foreign Entities

We now have only 36 days to go until August 1, 2013, when the new data collection obligations imposed on “applicable manufacturers” and group purchasing organizations under the physician payment “sunshine” rules of the...more

The Life Sciences Report - Spring 2013

In this issue: - Best Patent Practices Under the America Invents Act - CMS Issues Final Rule for Implementing Sunshine Act - New IP Litigation Team a Boon for Firm's Life Sciences and Technology...more

CMS Conducts First Call on Physician Payments Sunshine Act Implementation

In anticipation of the start of data collection under the Physician Payments Sunshine Act, the Centers for Medicare & Medicaid Services (“CMS”) continues to issue guidance on data collection and reporting in an effort to...more

White Collar Watch - April 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

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