Pause – CMS Spend Transparency Reporting Proposed Rule Published
Just when you thought it might all be a bad dream, the Physician Payments Sunshine Provisions proposed rule emerges. Last week, the Department of Health and Human Services (HHS) Centers for Medicare and Medicaid Services (CMS) finally released the long-awaited proposed rule requiring applicable manufacturers of drugs, devices, biological or medical supplies to report payments or other transfers of value (PTOV) provided to covered recipients. The proposed rule also includes the reporting requirements for applicable manufacturers and group purchasing organizations (GPOs) on certain physician ownership or investment interests.
There is a lot to digest, so click here for the “no-huddle” highlights of the proposed rule.
In the meantime, assemble the core team of the spend transparency governance body in your organization. As you documented in your charter, begin the review process of the CMS proposed rule to determine how your organization interprets it. You should already have a meeting on the books for the first week of January 2012 to compare notes on the rule and prepare comments to provide to CMS by no later than February 10, 2012, leaving time to review, finalize and deliver your remarks to CMS by February 17, 2012 at 5:00 ET. Divide review responsibilities into consumable components, break out the Kindle, iPad, or whichever device you just received as a holiday gift, load the PDF onto it and dig in. It actually makes for decent lavatory reading.
- Darryl Williams's blog
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