As described in a blog post earlier in February, the Centers for Medicare & Medicaid Services (CMS) has released the Final Rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act).

The Final Rule provides manufacturers and group purchasing organizations (GPOs) with guidance on a number of issues left open by the December 2011 Proposed Rule (the Proposed Rule) and differs from the Proposed Rule in several key aspects. Mintz Levin has prepared a chart summarizing the differences between the Proposed Rule and the Final Rule.

Most importantly, the Final Rule requires manufacturers and GPOs to begin collecting the required data on August 1, 2013 and to report the remaining calendar year 2013 data to CMS by March 31, 2014.

Mintz Levin is continuing to review the Final Rule, and we will publish additional educational materials in the coming weeks. Please check back regularly for updates and additional information.