On Feb. 1, 2013, the Centers for Medicare & Medicaid Services (CMS) published a final rule describing the National Physician Payment Transparency Program, often referred to as the “Sunshine” rule. The rule finalized procedures and processes whereby manufactures or drugs, devices, biologicals, or medical supplies provided under Medicare, Medicaid or CHIP must” report annually to the Secretary certain payments or transfers of value provided to physicians or teaching hospitals.” Additionally, “applicable manufacturers and applicable group purchasing organizations (GPOs) are required to report annually certain physician ownership or investment interests.” 

The program, which is mandated by the Affordable Care Act, seeks to clarify financial relationships between physicians and manufacturers and reduce the potential for conflicts of interest. The new program will begin on Aug. 1, 2013.  Applicable manufacturers will be given until March 31, 2014 to report data for the period of Aug. 1 – Dec. 31, 2013.  The data will then be posted to a public website by Sept. 30, 2014.