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Sunshine Act is Coming…Late but Definite

Recently, the FDA/CMS announced the delayed ruling on the Sunshine Act. There are a few notable changes from previous FDA/CMS guidelines for both manufacturers and providers.

1 The required notification period when data collection should begin has been doubled from a 3 month to a 6 month period. This will give manufacturers and group purchasing organizations a little extra time to get their ducks in a row.

2 Physician reporting and data collection about payments, gifts and other transfers of value given to physicians and teaching hospitals (greater than $10) will become mandatory  August 1, 2013. Manufacturers and GPOs are required to submit a first round of data to the CMS by March 31, 2014. Data must then be submitted on an annual basis by the 90th day of each subsequent calendar year.Although manufacturers and GPOs have bought a little more time under the finalized ruling, the timing and scope of the ruling is now finalized.

With Sunshine Act speculation officially over, it’s time to take a fresh look at your physician-level spending strategies at the physician level. To learn more about optimizing your KOL resource allocation strategies via organic physician influence network interactions Contact Us.

Download the official pre-relsease document below. The official release will be available on February 8th.
Pre-Published finalized document

Official Ruling available February 8th: Medicare, Medicaid, Children’s Health Insurance Programs: Transparency Reports and Reporting of Physician Ownership or Investment Interests
Final Document Available February 8th

About the Author

Lisa HaleyVP MarketingView all posts by Lisa Haley