Executives at life science companies have known for some time that the final rule implementing the Physician Payment Sunshine Act,¹ part of the Patient Protection and Affordable Care Act, would likely have a significant impact on their operations. The rule requires medical device and drug companies to start tracking payments and “transfers of value”—such as gifts, honoraria and ownership interests—made to physicians and teaching hospitals.
To be in compliance, the tracking must begin on August 1, 2013, and data collected during the next four months must be submitted to the federal Centers for Medicare and Medicaid by March 31, 2014.² “Preparation for complying with the new rule varies considerably among pharmaceutical, medical device and medical supply companies,” says Terry Hisey, vice chairman and principal, Deloitte LLP, and U.S. Life Sciences sector leader.
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