Thursday, March 27, 2014

Asking more about the Sunshine Act

Even though it is just implemented in the past years some of the people are having the hard time when it comes to the Sunshine Act. The Physician Payments Sunshine Act deadline is fast approaching. The new law has already taken effect, so hopefully you’ve already heard of it and taken steps to prepare. If not, you need to review the reporting requirements as soon as possible, and prepare what may be a lot of detailed information in just a few days.

For those who may be new to the medical industry, or for those who need a quick recap, we’ve compiled a list of the most frequently asked questions related to Sunshine Act reporting below.

Question #1:Who needs to comply with the Sunshine Act? Drug manufacturers, medical device manufacturers, and medical supply manufacturers operating in the US must report all monetary and/or value information transactions made to physicians and/or teaching hospitals.

Question #2: What must be reported? Items that must be reported include: any payments or value transfers of $10 or more made to physicians and/or teaching hospitals. Third party payments or transfers (i.e., payments or transfers made by a third party on behalf of a physician), or entity transfers (i.e., payments or transfers made to an organization with instructions to provide those payments or transfers to a specific physician or group of physicians) must also be reported.

Question #3: What are the penalties for failing to comply with the reporting requirement? Fines for noncompliance range from $1,000 to $10,000 for each unreported item, with a maximum penalty of $1,000,000 per organization.

Question #4: What are the key dates you need to know? August 1, 2013 – Manufacturers and GPOs must begin collecting data December 31, 2013 – The last day of data collection for the 2013 report March 31, 2014 – 2013 report deadline May 15, 2014 – Last day for physicians to review and dispute reported 2013 data before information is made public September 30, 2014 – First day 2013 data is posted to a public website

Question #5: What does each entry need to include? Each entry should include the physician/hospital name, NPI, primary specialty code, practice name, and practice address. The product name, details about the product, the nature of the benefit, and the amount of the expense must also be included.

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