Navigating the Physician Payment Sunshine Act

The Centers for Medicare & Medicaid Services (CMS) has released the long-awaited final regulation implementing the Physician Payments Sunshine Act, also referred to as the PPSA or Sunshine Act.

The law, passed as part of the Patient Protection and Affordable Care Act, requires public reporting by manufacturers of medical products and group purchasing organizations (GPOs) of all payments or transfers of value to physicians and teaching hospitals, as well as ownership or investment interests held by physicians or immediate family members of physicians in such manufacturers and GPOs.

Although required by Congress to implement the law and begin data collection by Jan. 1, 2012, the lengthy delays in the release of the proposed and then final regulations by CMS mean that data collection will not begin until Aug. 1, 2013. This will delay reporting by applicable manufacturers and GPOs to CMS until March 31, 2014 and public reporting until Sept. 30, 2014.

The American College of Cardiology has developed a set of frequently asked questions to help navigate the Sunshine Act.