The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule giving pharmaceutical and medical device manufacturers as well as group purchasing organizations some insight into how CMS intends to implement the Physician Payment Sunshine Act, which was enacted as part of health care reform. In an article published in BNA’s Health Care Fraud Report, Tom Crane, Karen Lovitch, and I discuss CMS’s proposed rule (which addressed certain crucial details but left many questions unanswered pending review of comments) and examine a number of the issues on which CMS has requested input.