What Is...The Physician Payments Sunshine Act or "Open Payments"?

    By Abraham Gitterman, Alan E Reider, Allison Weber Shuren, Daniel Kracov and Lauren Nicole Miller

    What Is...The Physician Payments Sunshine Act or "Open Payments"?

    What Is...The Physician Payments Sunshine Act or "Open Payments"?

    By Abraham Gitterman, Alan E Reider, Allison Weber Shuren, Daniel Kracov and Lauren Nicole Miller

    The Sunshine Act requires applicable manufacturers of drugs, biologics, devices, or medical supplies covered under Medicare, Medicaid, or the Children's Health Insurance Plan (CHIP) to report annually to the Centers for Medicare and Medicaid Services (CMS) in an electronic format, payments or transfers of value made to "covered recipients"--physicians and teaching hospitals.

    What Is...The Physician Payments Sunshine Act or "Open Payments"?

    By Abraham Gitterman, Alan E Reider, Allison Weber Shuren, Daniel Kracov and Lauren Nicole Miller

    What Is...The Physician Payments Sunshine Act or "Open Payments"?

    What Is...The Physician Payments Sunshine Act or "Open Payments"?

    By Abraham Gitterman, Alan E Reider, Allison Weber Shuren, Daniel Kracov and Lauren Nicole Miller

    The Sunshine Act requires applicable manufacturers of drugs, biologics, devices, or medical supplies covered under Medicare, Medicaid, or the Children's Health Insurance Plan (CHIP) to report annually to the Centers for Medicare and Medicaid Services (CMS) in an electronic format, payments or transfers of value made to "covered recipients"--physicians and teaching hospitals.

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    This guide provides a detailed overview of the Sunshine Act, transparency initiatives, and related implications associated with increased attention on physician-industry relationships.

    • Section II provides background and the legislative history of the Sunshine Act.
    • Section III provides a detailed summary and analysis of the technical statutory and regulatory requirements manufacturers and group purchasing organizations must abide by to comply with the law.
    • Section IV analyzes the Sunshine Act's regulatory requirements as they may impact other healthcare fraud and abuse and compliance obligations and requirements, including the Anti-Kickback Statute and the False Claims Act.
    • Section IV.C provides an overview of related state transparency laws and gift ban laws, including how such provisions are preempted under the Sunshine Act.
    • Section V offers a brief overview of CMS's first data release on the Open Payments website and discusses potential issues and future concerns for all stakeholders moving forward.

    As a bonus at the end of this guide you will find:

    • Appendix A - Table of U.S. Transparency, Gift Ban Requirements
    • Appendix B - District of Columbia
    • Appendix C - Massachusetts
    • Appendix D - Nevada
    • Appendix E - Vermont

    Product Details

    Publishers

    ABA Book Publishing

    ISBN

    9781634252928

    Product Code

    5630134EBK

    Publication Date

    7/22/2015 12:00:00 AM

    Publishers

    ABA Book Publishing

    ISBN

    9781634252911

    Page Count

    124

    Product Code

    5630134

    Trim Size

    6x9

    Publication Date

    7/10/2015 12:00:00 AM

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