A Word About the Sunshine Act

The Physician Payments Sunshine Act requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal health care programs to report certain payments and items of value given to physicians and teaching hospitals. The Centers for Medicare & Medicaid Services (CMS) has been charged with implementing the Sunshine Act and has called it the Open Payments Program. While faculty honoraria and expenses associated with accredited CME may be excluded from the reporting requirements, final determination as to the reportability of certain payments to faculty is made by the manufacturers. Faculty members are not required to register with CMS, however are encouraged to do so in order to be able to challenge any information that the manufacturers propose to publish in their annual reports.