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The Sun is Rising: What You Need to Know About the Final Rule to Implement the Physician Payments Sunshine Act

19 Feb 2013, 1:00 PM - 2:30 PM (Eastern Time)                            

On Tuesday, February 19, 2013, from 1:00 - 2:30 P.M. Eastern Time, King & Spalding will host a Roundtable Webinar focused on the final rule to implement the federal Physician Payments Sunshine Act that was recently released by the Centers for Medicare and Medicaid Services (“CMS”).

The Physician Payments Sunshine Act requires certain pharmaceutical, biologic, and medical device manufacturers to annually report to CMS payments or other transfers of value they furnish to physicians and teaching hospitals (deemed “covered recipients”). In addition, the law requires certain manufacturers and group purchasing organizations to report ownership or investment interests in their organizations held by physicians. CMS is required to aggregate the information manufacturers and group purchasing organizations submit and make it publicly available through a searchable website.

The final rule requires manufacturers to begin collecting data regarding payments or other transfers of value provided to covered recipients by August 1, 2013. Similarly, manufacturers and group purchasing organizations must also begin tracking ownership or investment interests held by physicians by August 1, 2013. First disclosure reports providing information about those interactions during the period from August 1, 2013 to December 31, 2013 must be electronically submitted to CMS by March 31, 2014. CMS will publicly post the reported information on its website by September 30, 2014.

The final rule has important implications for life sciences manufacturers and health care professionals and organizations. All interested stakeholders should understand the rule’s effects on their day-to-day activities, as well as how these new requirements may impact the perceptions of customers, patients, media outlets, and enforcement authorities.


  • Brian Bohnenkamp

  • Connie Dotzenrod

  • Bev Lorell, M.D.

  • Seth Lundy


The Roundtable will include the following topics:

  • Which manufacturers are required to comply with the new requirements

  • Which individuals and entities are covered recipients under the new requirements

  • The types of payments, materials, items, and other benefits subject to disclosure, as well as those that are excluded from disclosure

  • The contents of disclosure reports that manufacturers must annually submit to CMS

  • The reporting of physician ownership and investment interests by manufacturers and group purchasing organizations, including which types of interests are not required to be disclosed

  • Opportunities for covered recipients to review data reported about them before it is made publicly available

  • How CMS will make reported information publicly available

  • Practical implications for manufacturers, physicians, and teaching hospitals

  • Enforcement implications

You can register to attend by Webinar by clicking the Register link at the bottom of this page.

General information on our practice is available on the K&S Website and in our electronic publication Serving the Healthcare Industry. If you would like to be included on our regular healthcare practice mailing list to receive notices of other events and written updates, you can be added by submitting your full contact information to


If you have questions concerning this Roundtable, contact Marie Parks at