News & Analysis as of

Data Collection Sunshine Act

Sheppard Mullin Richter & Hampton LLP

On Your Mark, Get Set, Go: Life Science Companies Face A Challenging Year For Compliance With New Open Payment Program Data...

The Physician Payment Sunshine Act (the “Sunshine Act”) – a federal law first adopted as Section 6002 of the Patient Protection and Affordable Care Act of 2010 (“PPACA”) – requires the Centers for Medicare and Medicaid...more

Foley & Lardner LLP

Sunshine Act Reporting Update: De Minimis Amounts

Foley & Lardner LLP on

The Centers for Medicare & Medicaid Services (CMS) issued updated guidance on the thresholds that Applicable Manufacturers and Group Purchasing Organizations are required to report annually under the Sunshine Act (42 U.S.C. §...more

Morgan Lewis - Health Law Scan

With Sunshine Act Submission Deadline Looming, CMS Announces Enforcement Discretion

The Centers for Medicare and Medicaid Services (CMS) issued an Open Payments COVID-19 Announcement on March 25 saying that it planned in some cases to exercise enforcement discretion with respect to late or incomplete data...more

Saul Ewing Arnstein & Lehr LLP

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

Mintz - Health Care Viewpoints

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

Morgan Lewis

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

Morgan Lewis on

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

Mintz - Health Care Viewpoints

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

Mintz - Health Care Viewpoints

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

Mintz - Health Care Viewpoints

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

Mintz - Health Care Viewpoints

CMS Publishes Final Sunshine Act Rule; Data Collection to Begin on August 1, 2013

The long-awaited final rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act) has arrived at the Federal Register. It amends key definitions and adds new terms; retains broad reporting...more

Mintz - Health Care Viewpoints

Let the Collection and Reporting Begin: CMS Publishes Final Sunshine Act Regulations

The long-awaited final rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act) has arrived at the Federal Register. It amends key definitions and adds new terms; retains broad reporting...more

King & Spalding

CMS Announces it Will Not Require Data Collection by Manufacturers under the Physician Payments Sunshine Act Before January 1,...

King & Spalding on

Margaret Tavenner, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS or the “Agency”), issued a letter to Senator Chuck Grassley on May 3, 2012 formally responding to a letter sent to her by Senator...more

Foley Hoag LLP

CMS Delays Sunshine Act Data Collection Until 2013 May 8, 2012

Foley Hoag LLP on

In a blog entry on May 3, 2012, CMS announced it was delaying the Sunshine Act requirement for data collection until January 1, 2013. CMS’s stated rationale was...more

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