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Sunshine Act's reporting requirements: Act now or forever hold your peace

As you may have heard, CMS proposed a rule related to the Physician Payment Sunshine Act that would make CME providers responsible for reporting monies from pharma that are indirectly spent on physicians—i.e., for things like honoraria and other faculty expenses, among other things (details here). Yesterday there was a special #CMEReg chat on Twitter on just this topic, with folks from the CME Coalition fielding questions from concerned providers (archives of the chat are here—thanks, Derek!).

If you aren't already familiar with the issues involved in this aspect of the proposed Sunshine Act, I would urge you do get up to speed (resources: here and here). And do it today, because the deadline to respond to the HHS is tomorrow, February 17. This could really affect your business, so please check into it and let HHS know what you think. (Submit comments here.)

Update: I forgot to mention that the Alliance for Continuing Education in the Health Professions also has weighed in on this issue (download a PDF of its response here). Not surprisingly, the Alliance has many of the same objections to this proposal as the CME Coalition. To quote from the Alliance letter to CMS:

"These potential consequences include: (1) reluctance on the part of physicians to serve as faculty or even to participate in industry-supported CME because the reporting requirements could result in the incorrect perception that these individuals are receiving some direct benefit from industry support; (2) burdensome reporting requirements for CME providers who already operate with limited resources and tight margins and would be required to determine the value of benefits that accrue to covered recipients attending CME programs; and (3) a reluctance on the part of commercial supporters to fund CME activities due to the difficulty in calculating, tracking and reporting the indirect benefit of their support on faculty and participants."

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