PHYSICIAN PAYMENTS SUNSHINE PROVISIONS REMAIN IN EFFECT
As has been widely reported, the Supreme Court affirmed the constitutionality of the Affordable Care Act this morning. Among other things, this means that the physician payment sunshine provisions of the Affordable Care Act ("Sunshine Act") will remain in effect. Thus, the Sunshine Act will require data collection and reporting to CMS by medical manufacturers and group purchasing organizations covered by the Sunshine Act for inclusion on a publicly available web site in 2013, following issuance of final rules expected later this year.
With the constitutionality of the Affordable Care Act now determined, companies covered by the Sunshine Act should consider taking action to make sure that their compliance programs and information systems will be ready when final rules have been issued.
View our May 8, 2012, December 19, 2011 and June 2, 2010 Client Alerts describing the Sunshine Act in more detail.
If you have questions about this client alert or would like more information, please contact a member of Oppenheimer's Medical Technology Team.
This alert is a copyrighted publication produced by Oppenheimer Wolff & Donnelly LLP. The information contained in this alert is of a general nature and is subject to change. Readers should not act without further inquiry and/or consultation with legal counsel.