 |
Matthew J. Murer
Practice Area Chair
Jane E. Arnold
Practice Area Vice-Chair
Colleen M. Faddick
Practice Area Vice-Chair
Alan K. Parver
Practice Area Vice-Chair
Janice A. Anderson
Douglas K. Anning
Jack M. Beal
Cynthia E. Berry
Mary Beth Blake
Mary Clare Bonaccorsi
Gerald W. Brenneman
Teresa A. Brooks
Jared O. Brooner
Anika D. Clifton
Anne M. Cooper
Lauren P. DeSantis-Then
S. Jay Dobbs
Thomas M. Donohoe
Cavan K. Doyle
Meredith A. Duncan
Erin Fleming Dunlap
Fredric J. Entin
Jennifer L. Evans
T. Jeffrey Fitzgerald
Michael T. Flood
Kara M. Friedman
Rebecca L. Frigy
Asher D. Funk
Randy S. Gerber
Mark H. Goran
Linas J. Grikis
Lauren Z. Groebe
Brett B. Heger
Jonathan K. Henderson
Margaret H. Hillman
Jay M. Howard
Cullin B. Hughes
Sara V. Iams
George Jackson, III
Bruce A. Johnson
Lindsay R. Kessler
Joan B. Killgore
Anne L. Kleindienst
Chad K. Knight
Sarah R. Kocher
Dana M. Lach
Jason T. Lundy
Ryan M. McAteer
Jane K. McCahill
Ann C. McCullough
Ryan J. Mize
Aileen T. Murphy
Hannah L. Neshek
Gerald A. Niederman
Edward F. Novak
Thomas P. O'Donnell
Aaron E. Perry
Mitchell D. Raup
Daniel S. Reinberg
Kristen B. Rosati
Donna J. Ruzicka
Charles P. Sheets
Kathryn M. Stalmack
Leah Mendelsohn Stone
Chad C. Stout
Steven K. Stranne
William E. Swart
Tennille A. Syrstad
Emily C. Tremmel
Andrew B. Turk
Joseph T. Van Leer
Andrew J. Voss
Joshua M. Weaver
Emily Wey
Mark R. Woodbury
Janet E. Zeigler
Additional Health Care
Professionals
Julius W. Hobson, Jr.
Harry Sporidis
To learn more about our
Health Care practice,
click here.
|
 |
 |
March 2013 |
| |
Physician Payment Sunshine Act Final Rule Released |
| |
Executive Summary
On February 8, 2012, the Centers for Medicare and Medicaid Services ("CMS") published a final rule ("Rule") for what is commonly referred to as the Physician Payment Sunshine Act ("Act"), which was passed as Section 6002 of the Affordable Care Act. The Act requires certain manufacturers of medical drugs, biologicals, and devices and certain group purchasing organizations (defined in the Rule as "applicable manufacturers" and "applicable GPOs") to report to CMS payments or other transfers of value made to certain physicians and teaching hospitals (defined in the Rule as "covered recipients") and certain physician owners or investors. CMS will make these reports available for public review. The Act is part of CMS' efforts to create greater transparency between medical manufacturing companies and providers, whose relationships have historically drawn scrutiny from CMS and other governmental agencies. The Rule requires applicable manufacturers and applicable GPOs to gather reportable data beginning on August 1, 2013 and submit their first reports on March 31, 2014. CMS will release the data publicly by September 30, 2014.
The Rule finalizes a number of key definitions and other provisions, including who must submit the required reports to CMS, what data must be submitted in the reports, what the process is for submission and review, how affected parties can dispute submissions, how the public can access the reports, and what the penalties are for failing to submit the reports.
This e-Alert provides an in-depth analysis of these key provisions in the Rule and their practical effect on affected manufacturers, GPOs, and providers.
Interpretation and Clarification of Key Definitions
Payment and Other Transfer of Value Report Content Reports
Reports of Physician Ownership and Investments
Report Submission Process
Review and Corrections Process
Public Availability
Record Retention and Audits
Penalties
Preemption
Practical Effects
[Click here to view the full PDF.]
For More Information
For questions, please contact:
|
| |
|
| |
|
Polsinelli Shughart | In the News |
Headlines and Bylines from polsinelli.com |
|
| |
|
|
|
|
| |
|
|
Serving corporations, institutions, entrepreneurs, and individuals, our attorneys build enduring relationships by providing legal counsel informed by business insight to help clients achieve their objectives. This commitment to our clients' businesses has helped us become the fastest-growing, full-service law firm in America*. With more than 630 attorneys in 16 cities, our national law firm is a recognized leader in the industries driving our growth, including health care, financial services, real estate, life sciences and technology, energy and business litigation. The firm can be found online at www.polsinelli.com. Polsinelli Shughart PC. In California, Polsinelli Shughart LLP.
* Inc. Magazine, September 2012 |
| |
|
 |
| |
To update your email preferences, please contact us at Interaction@polsinelli.com. To opt out of these communications, click the unsubscribe link below.
Polsinelli Shughart provides this material for informational purposes only. The material provided herein is general and is not intended to be legal advice. Nothing herein should be relied upon or used without consulting a lawyer to consider your specific circumstances, possible changes to applicable laws, rules and regulations and other legal issues. Receipt of this material does not establish an attorney-client relationship.
Polsinelli Shughart is very proud of the results we obtain for our clients, but you should know that past results do not guarantee future results; that every case is different and must be judged on its own merits; and that the choice of a lawyer is an important decision and should not be based solely upon advertisements.
Polsinelli Shughart PC. In California, Polsinelli Shughart LLP. Polsinelli Shughart® is a registered trademark of Polsinelli Shughart PC.
Copyright © 2013 Polsinelli Shughart PC ®.
|
|
