BC Advantage - 2021 Issue 7

Shining Light on the Physician Open Payments Program (f/k/a Sunshine Act) and False Claims Act Violations

As part of its obligation to implement Section 6002 of the Affordable Care Act-the Physician Payment Sunshine Act ("Sunshine Act"), in February 2013, the Centers for Medicare and Medicaid Services (CMS) released the final regulations for implementation.  The fundamental premise behind the Sunshine Act was to promote greater transparency and shed light on financial relationships between doctors and manufacturers of covered drugs, devices, biologicals, and medical supplies (collectively "Manufacturers"). Teaching hospitals or academic medical centers have a similar requirement. The reporting requirements, which stem back to March 31, 2014, are as follows:Physicians and teaching hospitals are...

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