In an effort to ensure transparency in the relationships between
manufacturers and distributors of pharmaceuticals, biologics,
medical devices, and medical supplies, the Patient Protection and
Affordable Care Act of 2009 (the "Health Reform Law")
requires Manufacturers to report payments or other transfers
of value in the 2012 calendar year to physicians and teaching
hospitals in electronic format by March 31, 2013, and on the 90th
day following each calendar year thereafter. For a detailed
discussion of the reporting requirements, see the recent
Strasburger Health Industry Online newsletter Manufacturers Must Soon Track and Report Payments to Health
Care Profressionls: Are You Prepared? On December
14, 2011, the Centers for Medicare and Medicaid Services
("CMS") issued a Proposed Rule in which it proposes to
delay the data collection by Manufacturers until the Final Rule is
issued sometime later in 2012. Depending on the timing of the
issuance of the Final Rule, CMS has proposed that Manufacturers
submit only a partial year report on March 31, 2013. CMS
posed several questions in the Proposed Rule and invited public
comment. The comment period is open until February 17,
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