Compliance Corner
CMS posts revised templates for data collection and submission of reports required by the Sunshine Act
By Rachael Garrison
The Centers for Medicare and Medicaid Services (CMS) is continuing its efforts to quickly implement the Transparency Reports and Reporting of Physician Ownership or Investment Interests section of the Patient Protection and Affordable Care Act, commonly referred to as the "Sunshine Act."
CMS publishes list of teaching hospitals subject to reporting under the Sunshine Act
By James Squier
Sunshine Act: CMS sends final regulations to the Office of Management & Budget
By Danielle Burke
On November 27, 2012, the Office of Management and Budget (OMB) received final regulations from the Centers for Medicare and Medicaid Services (CMS), which would implement the "Transparency Reports and Reporting of Physician Ownership or Investment Interests" section of the Patient Protection and Affordable Care Act. CMS previously missed the October 1, 2011, deadline to establish regulations implementing this section, which is commonly referred to as the "Sunshine Act." The text of the final regulations is not currently available for viewing.
Proposed Mass. law allowing drug and med-tech makers to provide modest meals to practitioners has been sent to the governor
Last week, the Massachusetts Senate and House of Representatives both passed House Bill 4200. Currently, Massachusetts’s Pharmaceutical and Medical Device Manufacturer Conduct Law, requires the Department of Public Health to “adopt a standard marketing code of conduct for all pharmaceutical or medical device manufacturing companies that employ a person to sell or market prescription drugs or medical devices in the commonwealth.”
A quick note on preemption…courtesy of the Vermont Attorney General’s Office

by Hiramella Deonarine and Ingrid Pelzer
Pursuant to Vermont’s Prescribed Products Gift Ban and Disclosure Law (Law), manufacturers of prescription drugs, biological products and medical devices are required to disclose to the Vermont Attorney General’s Office (AG’s Office) the value, nature, purpose, and recipient of any allowable expenditure or permitted gift.
The sun’ll come out tomorrow…or not…House members ask CMS to delay implementing the Sunshine Act

by Ingrid A. Pelzer
CMS announces it will not require data collection by manufacturers or GPOs pursuant to the Sunshine Act before January
by Ingrid A. Pelzer
In December 2011, the Centers for Medicare and Medicaid Services published draft regulations that would implement the "Transparency Reports and Reporting of Physician Ownership or Investment Interests" section of the Patient Protection and Affordable Care Act, commonly referred to as the Sunshine Act.
The Massachusetts House of Representatives has voted to repeal the Pharmaceutical and Medical Device Manufacturer Conduct Law
by Ingrid A. Pelzer
The Massachusetts House of Representatives recently voted on and passed its proposals for the commonwealth’s Fiscal Year 2013 budget. The proposal included Consolidated Amendment I, which would repeal the Pharmaceutical and Medical Device Manufacturer Conduct Law [Mass. Gen. Laws Ch. 111N].
Vermont Attorney General’s Office Releases the “Prescribed Product Disclosures: Report of Vermont Attorney General William H. So
by Ingrid A. Pelzer
Vermont’s Prescribed Product Disclosure Law requires manufacturers of prescribed products to annually disclose to the Vermont Attorney General’s Office the value, nature, purpose, and recipient of any allowable expenditure or permitted gift by October 1, 2011.
Senators Grassley and Kohl Send Another Letter to CMS Regarding Implementation of the Sunshine Act
by Ingrid Pelzer