Bracing for the Physician Payment Sunshine Act

Topic Brief for Biopharmaceutical Firms and Medical Technology Suppliers

About the Topic Brief

Following much anticipation on the part of health care industry members, CMS released its long-awaited final rule on the Physician Payment Sunshine Act in February 2013, clarifiying new financial disclosure requirements governing pharmaceutical and medical device manufacturers.

The rule includes extensive and potentially time-consuming mandates for drug and device companies, including reporting of annual payments to physicians and teaching hospitals.

The costs for noncompliance are substantial: applicable manufacturers face stiff civil monetary penalties (CMP) from $150,000 to $1,000,000 for deficient reporting.

Read on for legal insight from Kyle Sampson from Hunton & Williams LLP on this topic and the consequences for your organization.

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