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An Introduction to the Sunshine Act

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Presentation on theme: "An Introduction to the Sunshine Act"— Presentation transcript:

1 An Introduction to the Sunshine Act
Health Care Industry Committee An Introduction to the Sunshine Act Ready-to-Use Presentation Slides

2 Introducing the Sunshine Act
Pharmaceutical, Device Companies Required to Report Gifts to Physicians Anticipated Effect of the Sunshine Act Close Monitoring of Value Transfers Applicable manufacturers required to closely track value transfers made to physicians Increased Transparency Patients, prosecutors, and public interest groups can access information on value transfers Greater Potential for Fraud, Abuse Complaints New transparency requirements mean that physicians are more likely to face fraud and abuse claims Law in Brief: The Open Payments Program (“Sunshine Act”) Passed as part of the Patient Protection and Affordable Care Act (ACA) Requires “applicable manufacturers” (like pharmaceutical and medical device companies) and Group Purchasing Organizations to annually report to CMS any payments or transfers of value they make to physicians and teaching hospitals in excess of $10 Reported information will be made publically available online Source: Advisory Board research and analysis.

3 From Recording to Reporting
Breaking Down the Sunshine Act’s Reporting Cycle 1 2 3 Pharmaceutical, medtech firms transfer value to physician(s) Firms submit information to CMS outlining value transfers made that year Physicians, medical groups have 45 days to review submitted information 6 5 4 Reported information updated during subsequent data releases Reported information is made public, accessible online Manufacturers have 15 days to resolve data disputes Source: Advisory Board research and analysis.

4 Establishing a Timeframe for Change
CMS Begins an Annual Reporting Process Key Dates in the 2013 Sunshine Act Reporting Period What Gets Reported Aug. 1 – Dec. 31, 2013 Applicable manufacturers collect data on value transfers made to physicians September 2014 CMS releases an online database of the reported information to the public Physician information: Name Business address National Provider Identifier (NPI) number Transaction information: What was transferred Value of goods, money transferred (including gifts, meals, speaking fees, etc.) Nature of the transaction Date it occurred March 31, 20141 Deadline for applicable manufacturers to report data to CMS Beginning an Annual Process In subsequent years applicable manufacturers will track information over 12 month intervals After 2014 the deadline will be 90 days after the new year begins Source: Advisory Board research and analysis.

5 Medical Groups Looking to Limit Risk
! Can Medical Groups Get Away With Doing Nothing? Although physicians and medical groups are not legally required to do anything to comply with the Sunshine Act, legal consultants from the firm Krieg Devault recommend that medical groups take the following steps to limit the risk of negative repercussions resulting from the act’s transparency requirements 1 Update Medical Group Policies Medical groups should make sure that their employment agreements, compliance policies, and conflict of interest disclosure procedures are up-to-date and ensure accurate financial records 2 Request a Pre-Submission Review To avoid false reporting, medical groups that know they will be reported on under the Sunshine Act should request to conduct a pre-submission review with applicable manufacturers 3 Actively Monitor any Information Submitted to CMS Medical group leaders should set aside time in April and May to take advantage of the 45-day window to review information submitted to CMS about their physicians 4 Require Physicians to Notify Medical Group Leaders of Outside Activities Groups should require their physicians to notify administrators of any activities they participate in that could be affected by these new transparency regulations Source: Advisory Board research and analysis.


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