Sunshine Act Quiz #3

Manufacturers do not need to track or report buffet meals, snacks, soft drinks, or coffee made generally available to all participants at conferences or similar large-scale events. The preamble specifies, however, that the exception does not apply when the manufacturer provides the meal to select attendees.

For example, an applicable manufacturer may hire a market research firm to conduct a double-blinded market research study, which includes paying physicians $50 for responding to a set of questions. The applicable manufacturer clearly intends a portion of the payment to be provided to physicians, but given that the reason for the third party's involvement is specifically to maintain the anonymity of the respondents and sponsor, CMS does not intend this to be considered a reportable indirect payment or other transfer of value. - See more at: http://www.policymed.com/2013/02/physician-payment-sunshine-act-top-50-things-to-know.html#sthash.wSqeA1QB.dpuf

Both are excluded: CMS agreed that “such an item, which is given to physicians for the purpose of educating patients, falls within the exclusion. Similarly, if a manufacturer provides educational materials to a physician on a flash drive to be distributed to patients, the flash drive would also fall within the exclusion. CMS also stated that overhead expenses, such as printing and time, should be included in the exclusion as long as they are directly related to the development of the materials, which directly benefit patients or are intended for patient use. - See more at: http://www.policymed.com/2013/02/physician-payment-sunshine-act-top-50-things-to-know.html#sthash.kImDnJYv.dpuf

The applicable manufacturer or GPO must include its name as well as the name of the covered recipient, specialty, business address, NPI number if available, and State professional license number. The data collected will also include the amount and date of the payment (or transfer of value); form and nature of the payment; name of the related drug, device or biological; and whether the payment is eligible for delayed publication (some research payments related to new products may be eligible for delayed reporting).