by Sarah K. Giesting, Wendy C. Goldstein, Kathleen A. Peterson, and Natasha F. Thoren
On December 14, 2011, the Centers for Medicare & Medicaid Services issued long-awaited proposed rules (“Proposed Rules”) related to the federal Physician Payment Sunshine Act applicable to pharmaceutical, medical device, biological and medical supply manufacturers and group purchasing organizations (“GPOs”). The Proposed Rules outline CMS’s proposals regarding implementation of the Physician Payment Sunshine Act and seek comments regarding these proposals. This health reform alert provides an overview of the Proposed Rules and then discusses some key considerations for manufacturers and GPOs as they evaluate and prepare comments to the Proposed Rules.
Tags: Agency Information, CMS, GPOs, group purchasing organizations, Physician Payment, Proposed Rules, Sunshine Act