Sunshine Act Preparations
The Physician Payments Sunshine Act requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal health care programs to report certain payments and items of value given to physicians and teaching hospitals. Industry began gathering data to report last August. The initial reporting period will be August 1, 2013 – December 31, 2013; subsequent reporting periods will be annual. The public release of the data is slated for September 30, 2014.
Physicians and teaching hospitals are able to register onto the CMS Enterprise Portal as of June 1, 2014, for the ability to review and potentially dispute the data reported about them. The June registration is phase 1, and phase 2 is expected to open in July. Phase 2 provides the opportunity to view the data.
There is no requirement that you register and review your data, but we strongly recommend that you do. This data will be made public at the end of September.
Your preparations for the implementation of the Sunshine Act should include:
1. Register on the CMS website
2. Internally track payments and items of value received, by whom and from whom
3. Be prepared to discuss this with patients – they will have questions and you want to provide a positive view
4. Review information on the CMS website and dispute any inaccuracies before September 30, 2014
Additional information about the program can be found at: http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Physicians.html
As always, we are here to help. Please let us know if you have any questions.