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Trends in Healthcare M&A

August 22, 2013

BY JAMES F. OWENS & PHILLIP H. STREET

August: A Month of Sunshine in More Ways Than One

As the regulatory spotlight continues to shine on this industry, August is a milestone month for some new provisions. Earlier this summer, the Centers for Medicare & Medicaid Services released its final rule interpreting the physician payment “sunshine” provisions of the Patient Protection and Affordable Care Act. With the data collection requirement beginning on August 1st, the Sunshine Act contains strict reporting requirements, particularly in light of the complex and numerous arrangements between applicable manufacturers, group purchasing organizations, and physicians and physician practices.

What does this mean for you? Given the potentially significant penalties (more than $1 million per manufacturer) for failure to comply with such strict reporting requirements, all professionals and organizations affected by the Sunshine Act should immediately start preparing for the Sunshine Act’s new transparency requirements. To see if you are affected and to learn more, click here.