Mintz Publishes Comparison of Proposed and Final Sunshine Act Regulations

By Karen S. Lovitch

As described in a blog post earlier today, the Centers for Medicare & Medicaid Services (CMS) has released the Final Rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act).

The Final Rule provides manufacturers and group purchasing organizations (GPOs) with guidance on a number of issues left open by the December 2011 Proposed Rule (the Proposed Rule) and differs from the Proposed Rule in several key aspects. Mintz has prepared a chart summarizing the differences between the Proposed Rule and the Final Rule.

Most importantly, the Final Rule requires manufacturers and GPOs to begin collecting the required data on August 1, 2013 and to report the remaining calendar year 2013 data to CMS by March 31, 2014.

Mintz is continuing to review the Final Rule, and we will publish additional educational materials in the coming weeks. Please check back regularly for updates and additional information. 

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    Karen S. Lovitch

    Chair, Health Law Practice & Chair, Health Care Enforcement Defense Practice

    Karen advises industry clients on regulatory, transactional, operational, and enforcement matters. She has deep experience handling FCA investigations and qui tam litigation for laboratories and diagnostics companies.