A blog by attorneys for anyone interested in or affected by The Sunshine Act.

CMS Updates Sunshine Act Guidance on CME Reporting

July 23, 2015
Ruselle W. Robinson

CMS moved a step closer to implementing the new continuing medical education (CME) reporting requirements with a recent update to the Law and Policy page on the Sunshine Act/Open Payments website.  You can review the updated Law and Policy page here:  http://www.cms.gov/OpenPayments/About/Law-and-Policy.html

In October 2014, CMS adopted several revisions to the Sunshine Act/Open Payments regulations.  The revisions included elimination of a reporting exclusion for payments and other transfers of value made to physician speakers at CME events that met certain accreditation standards.

Beginning January 1, 2016, applicable manufacturers must collect data on indirect payments they make to organizers of a physician CME event if the applicable manufacturer learns the names of the physician attendees/speakers either within the reporting year, or by the end of the second quarter of the following reporting year.  Applicable manufacturers will report 2016 payment data to CMS in early 2017.

I wrote about the October 2014 regulatory revisions, including the change to the CME reporting requirement, in my blog post of November 28, 2014.  Here is link to that post: http://www.sunshineactpbl.com/cms-issues-final-amendments-sunshine-act-regulation/

I will continue to keep you apprised of Sunshine Act developments as they occur.  Stay tuned.

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