“Getting Ready for the Sunshine Act”
Medical Office Today 07/25/12 By Alyce C. Katayama
The Sunshine Act became law on March 23, 2010. It requires manufacturers of drugs, devices, biological, and medical supplies to report to HHS payments and “transfers of value” to physicians and teaching hospitals.
It also requires these manufacturers and group purchasing organizations (GPOs), including those owned by physicians, to submit reports regarding ownership or investment interests held by physicians or their immediate family members. The Sunshine Act does not prohibit the reported payments or ownership interests.
Transparency reports are required for a single payment or transfer worth $10 or more or cumulative payments/transfers of $100 or more in a calendar year. Payments/transfers below the $10/$100 thresholds are exempt from reporting. Also exempt are ownership or investment interests in a publicly traded security/mutual fund. Transfers of educational materials to benefit patients, short-term loans of medical devices, rebates, discounts, and items provided under warranty are also not reportable.
Originally published in Medical Office Today, July 25, 2012