Sunshine Act Task Force
ISMPP established the Sunshine Act Task Force to follow the issues, understand the details and implications, and, most importantly, provide information and tools to our membership with respect to medical publications and the Sunshine Act, Section 6002, Transparency Reports and Reporting of Physician Ownership or Investment Interests of the Patient Protection and Affordable Care Act, referred to as the National Physician Payment Transparency Program: Open Payments.
Update on Sunshine Act Interpretation, February 2014
ISMPP has prepared an update on the interpretation of the Sunshine Act Rules for Implementation. This update addresses several points of view: yes publications support is a reportable TOV, no it is not, and it depends on the circumstances. Details for each of these interpretations are covered in the document. As you read the document, please bear in mind that based on the differing interpretations by industry companies, there may be other categories of interpretation that are not covered.
Click here to view the update prepared by the ISMPP Sunshine Act Task Force on interpretation of the Sunshine Act.
ISMPP Sunshine Act Task Force Suggestions Document, August 2013
Click here to view the Task Force’s suggested approaches for interpretation and implementation of the Sunshine Act requirements.
Disclaimer: The approaches and suggestions regarding interpretation and implementation of the Sunshine Act offered to ISMPP members are based on the research of the Task Force and should not be construed as legal advice. Members are advised to seek individual legal guidance on how their company interprets the law.
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CMS update on the timeline for data submission
The CMS has announced an update to the process and timeline for reporting the first round of data. There is now a 2-phase process: Phase 1, which runs February 18 – March 31, 2014, is the registration period. Phase 2, the data submission period, is now slated to begin in May (specific date not provided), and will be open for at least 30 days. Both phases of data submission will be complete by August 1, and at that time healthcare providers and manufacturers will have an opportunity to review and correct inaccuracies. For details, please access:
Disclaimer: CMS updates its website frequently. ISMPP will make every effort to keep this link current.
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We encourage you to submit your questions, comments, and/or concerns regarding the Sunshine Act and Open Payments Program and its impact on medical publications. We’d also like to hear from you about what you and/or your organization has done or is in the process of implementing to meet the reporting requirements. Please email us at: firstname.lastname@example.org
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