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Mintz Levin Publishes Comparison of Proposed and Final Sunshine Act Regulations

As described in a blog post earlier in February, the Centers for Medicare & Medicaid Services (CMS) has released the Final Rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act).

The Final Rule provides manufacturers and group purchasing organizations (GPOs) with guidance on a number of issues left open by the December 2011 Proposed Rule (the Proposed Rule) and differs from the Proposed Rule in several key aspects. Mintz Levin has prepared a chart summarizing the differences between the Proposed Rule and the Final Rule.

Most importantly, the Final Rule requires manufacturers and GPOs to begin collecting the required data on August 1, 2013 and to report the remaining calendar year 2013 data to CMS by March 31, 2014.

Mintz Levin is continuing to review the Final Rule, and we will publish additional educational materials in the coming weeks. Please check back regularly for updates and additional information.

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About this Author

Karen Lovitch, health care, Medicare, Compliance, Licensing, MIntz Levin

Karen is the Practice Leader of the firm’s Health Law Practice. She counsels health care clients on regulatory, transactional, and operational issues, including Medicare coverage and reimbursement, the development and implementation of health care compliance programs, and licensure and certification matters. In addition, Karen advises clients on the legal, practical, and fraud and abuse implications of business arrangements and sales and marketing practices. Her experience includes matters related to the anti-kickback statute, the Stark law, state statutes prohibiting kickbacks and self-...