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Time Crunch – Sunshine Act

Life science companies must start tracking payments to physicians and teaching hospitals


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Executives at life science companies have known for some time that the final rule implementing the Physician Payment Sunshine Acti (“Sunshine Act”) would have a significant impact on their operations. The rule requires medical device and drug companies to start tracking payments and “transfers of value.” Companies must track these payments starting August 1, 2013, so they have very little time to prepare their processes and systems for compliance.ii How well prepared are companies to meet the deadline? The answer varies considerably among pharmaceutical, medical device, and medical supply companies. However, based on our experience in helping companies prepare their business processes and systems for compliance, we have identified four key areas, where companies can take action as they prepare to begin collecting the necessary data by August 1. These include:

  • Empowering decision makers
  • Making smarter trade offs
  • Cleaning up your data
  • Automating with a human touch

Companies need to make decisions quickly and may need to make significant investments across a range of areas if they want to meet the deadline. This means companies should thoroughly understand the requirements as stated in the final rule; identify and assess gaps in their infrastructure and processes; create a plan to achieve their tracking and reporting responsibilities; and manage change as they go through the process of collecting, validating, and reporting spend data.

Download the article to obtain more insights into how the Sunshine Act may impact your organization.

i The Sunshine Act is part of the Patient Protection and Affordable Care Act, which was signed into law March 2010 by President Obama.
ii The data collected between August 1 and December 31, 2013 must be submitted to the Centers for Medicare and Medicaid (CMS) by March 31, 2014. 78 Fed. Reg. 9458 (Feb. 8, 2013).

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