What is the Best Way for Manufacturers and Physicians to Apply Sunscreen to Avoid Being Burned by the Final Sunshine Act Regulations?

February 2013

This issue of Policy Forum (Volume 3, Number 4, February 27, 2013) explains the requirements under the Patient Protection and Affordable Health Care Act’s Physician Payment Sunshine Act that all medical product manufacturers report to Health and Human Services (HHS) any payment or transfer of value made to physicians and teaching hospitals.  Author Abraham Gitterman, Research Associate at Rockpointe, Inc., warns that manufacturers may face adverse consequences of public access to payment data, including fraud and abuse investigations and private litigation actions.  He recommends that manufacturers begin training employees to ensure compliance with the statute and reduce the likelihood of further investigations.  He further suggests that the Center for Medicare & Medicaid Services (CMS) include contextual information about physician-industry relationships when making payments public in order to minimize harming the reputations of physicians.  Gitterman concludes that if CMS’ implementation of the Sunshine Act stigmatizes collaborations between physicians and industry, medical progress will be slowed and patients will be harmed.

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