On February 1st, the Centers for Medicare & Medicaid Services (CMS) released the long-awaited final rule (Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act).  The Sunshine Act requires manufacturers of drugs, devices, biologics, or medical supplies covered by Medicare, Medicaid, or the Children’s Health Insurance Program (Manufacturers) to collect and report payments and other transfers of value to physicians and teaching hospitals, and also requires Manufacturers and Group Purchasing Organizations (GPOs) to disclose ownership or investment interests held by physicians or their immediate family members.

Of immediate importance for Manufacturers and GPOs, the Final Rule provides that applicable manufacturers and applicable GPOs must begin to collect the required data on August 1, 2013 and report the data to CMS by March 31, 2014.

Mintz Levin is analyzing the Final Rule in detail and preparing educational materials and resources.  We will provide further updates.