Ripe For Comment: The CMS Sunshine Rule

Law360, New York (December 22, 2011, 2:55 PM EST) -- The Centers for Medicare & Medicaid Services recently issued a long-awaited proposed rule to implement the Physician Payments Sunshine Act. The Physician Payments Sunshine Act, which was enacted in March 2010 as Section 6002 of the Patient Protection and Affordable Care Act, requires pharmaceutical and medical device manufacturers to report annually the payments and other “transfers of value” they make to physicians and teaching hospitals.

Under the Physician Payments Sunshine Act, companies were supposed to begin collecting data about payments and other transfers of value on...
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