April 22, 2013

Sunshine Series – Installment Two – CMS Publishes Fact Sheets and FAQs

In an effort to assist our clients and friends with implementation of the final regulations promulgated pursuant to the Physician Payment Sunshine Act (Section 6002 of the Patient Protection and Affordable Care Act), we will be providing updates in a "Sunshine Series" of emails. Our Sunshine Series will provide information on the government's preparations for information collection and publication (and eventual enforcement), practical tips for compliance, interesting nuances in the final regulations, State law preemption, and responses to general-interest questions posed by our clients.

The Centers for Medicare and Medicaid Services (“CMS”) recently published four Fact Sheets to provide information about the National Physician Payment Transparency Program, known generally as the Sunshine Law but referred to by CMS as “Open Payments.” The four Fact Sheets target different segments of the affected industry:

(1) Applicable Manufacturers;
(2) Applicable Group Purchasing Organizations;
(3) Teaching Hospitals; and
(4) Physicians.

While the Fact Sheets generally do not include new information, they evidence CMS’ outreach efforts and hopefully are the first of many educational efforts as we near the August 1, 2013 collection kick-off.

CMS also released a number of FAQ responses. We will summarize a few of the more interesting FAQs in the coming days.

The Fact Sheets and FAQs can be found on CMS’ Open Payments website, at http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/index.html

For more information, please contact:

H. Carol Saul
404.873.8694 - direct

Jennifer D. Burgar
404.873.8194 - direct

Lanchi N. Bombalier
404.873.8520 - direct

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