Neurologists should begin retaining their own records of items of value received from pharmaceutical companies and device manufacturers to ensure they are prepared to evaluate and challenge the accuracy of reports submitted by these entities to the Centers for Medicare and Medicaid Services (CMS). CMS recently issued a final rule implementing the Physician Payments Sunshine Act (Sunshine Act). According to CMS, the rule is designed to promote transparency in the financial relationships between physicians and industry. Starting August 1, pharmaceutical companies and device manufacturers must begin tracking payments and gifts of $10 or more given to physicians for 2013 and submit the data to CMS by March 31, 2014. In addition, these entities will have to report physicians' ownership or investments in these organizations. CMS confirmed, however, that publicly traded securities (i.e. 401K) are excluded from the regulation and will not be reported to CMS.
Below is a snapshot of important dates for 2013:
For years 2014 and beyond:
With only a 60–day period for dispute resolution, neurologists need to respond quickly to improve the chances of resolving discrepancies.
In response to concerns raised by the AAN, the Sunshine Act excludes certified and accredited continuing medical education events attended by physicians. The rule also excludes product samples intended for patients, educational materials that directly benefit patients and in–kind items for charity care.