Thought Leadership

On December 14, 2011, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule providing details for implementing the Physician Payment Sunshine Act (Sunshine Act) provisions under the Patient Protection and Affordable Care Act (PPACA).

The proposed rule confirms that manufacturers of drugs, devices, biologicals and medical supplies covered by Medicare, Medicaid, or the Children’s Health Insurance Program are required to report to CMS payments or other transfers of value they make to physicians and teaching hospitals. The proposed rule will also require manufacturers and group purchasing organizations (GPOs) to disclose to CMS physician ownership or investment interests.