Sunshine Act Reporting Summary
Reporting under the Sunshine Act
The Sunshine Act ultimately aims to see all payments and valued items given to doctors or hospitals accurately reported. In addition, the act makes the financial connection between healthcare providers, medical devices, and drug manufacturers more transparent.
Manufacturers of drugs, medical devices, biologics, and medical supplies, as well as group purchasing organizations (GPOs), are required to report services, payments and investment interests given to doctors and teaching hospitals to the CMS under the Physician Payments Sunshine Act.
All Sunshine Act reporting must be made available to the public so that interested parties can see potential financial relationships between suppliers and healthcare providers.
As part of the Patient Protection and Affordable Care Act (PPACA), the Obama administration passed the Sunshine Act. Sunshine Act reporting requirements aim to increase openness concerning financial ties between medical device suppliers, pharmaceutical corporations, doctors, and teaching institutions.
So who is required to report under the Sunshine Act?
There are three main groups that must report according to the Sunshine Act, these include:
- Teaching hospitals
- Group purchasing organizations
Of course, there are more complexities within the system. For example, physicians, who are not contractual employees of the reporting entity, must disclose compensation, apart from resident physicians.
Additionally, teaching hospitals that get paid for hosting medical education programs must disclose the amounts received.
As of 2018, the Sunshine Act expanded to include even more healthcare providers, including physician assistants, clinical nurse specialists, nurse practitioners, midwives, and nurse anesthetists. Therefore, any financial or transfers of value between this expanded group of healthcare professionals and drug or device manufacturers must be reported to CMS as of 2020.
The Sunshine Act reporting requirements demand that doctors, hospitals, and GPOs account for any investments or other financial contributions received, including stakes held in related businesses. This, again, aims to ensure that all financial transactions are recorded to help catch potential cases of bribery.
It is important to note that the Sunshine Act requires healthcare professionals to report financial ties or investments held by family members in relevant pharma companies.
What transactions are covered by Sunshine Act reporting requirements?
Payments, meaning all transfers of monetary value, must be reported to CMS. According to the Sunshine Act, these payments can fall into multiple categories and must be reported to CMS within a predetermined period. Therefore, healthcare providers must understand which transactions fall under the expanding payment category in order to make the necessary reports.
Some notable and reportable transactions that healthcare professionals are likely to come across include lodging, travel, consultancy fees, food, drink, research, honoraria, and investments. Individuals will need to report ownership interests, even if they are just a prospect.
Of course, this is not a definitive list of reportable payments. A more comprehensive list can be found in the 42 CFR and 403.904 nature of payments.
The various Sunshine Act reporting requirements are meant to limit the improper financial influence on research, education, and clinical decision-making involving patients.
Understanding which payments must be reported and when can be complicated and time-consuming. You can simplify your reporting process by utilizing the expertise of compliance specialists like MedCompli.
MedCompli can assist with all aspects of Sunshine Act reporting requirements, from data review to formatting and timely submissions. So get in touch with the MedCompli team today to lift the weight of Sunshine Act reporting and compliance off your shoulders.