Home > Property & Casualty > Implementation of Federal Sunshine Law delayed for drug and medical suppliers

Implementation of Federal Sunshine Law delayed for drug and medical suppliers

The Centers for Medicare and Medicaid Services (CMS) released guidance back in December regarding the implementation of the Federal Sunshine Law and the proposed timing. Since then, the timeline for formal introduction of the law has been revised by CMS, delaying how soon those manufacturers must begin to collect data for their reports. Rather than requiring the collections to begin on January 1st, CMS will not require them to begin until the issuance of the law’s final ruling.

This law will require manufacturers of drugs, biologics, devices and medical supplies covered under Medicare, Medicaid and the Children’s Health Insurance Program to report payments and other transfers of value made to physicians and teaching hospitals to CMS for subsequent public disclosure.

CMS has also taken on a more flexible approach toward the issued proposals, inviting comments, feedback and alternative proposals as well. Nevertheless, life science manufacturers should be aware of the impending requirements.

Our colleagues at Ropes & Gray have provided a detailed analysis of the proposed rule and CMS commentary, click here to view. Or for more information, contact a member of the WGA Life Sciences team.

About the Author

Jamie Balboni, is a Principal at WGA and Property & Casualty Practice Leader. She specializes in guiding clients through the complexities associated with creating the broad global insurance programs necessary to compete in today’s economy.

617.646.0247   JBalboni@wgains.com   Connect with Jamie on LinkedIn


  1. May 4, 2012 at 6:49 am

    Most useful information. I like it…

    Wilmington nc attorney

  1. No trackbacks yet.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s