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AAMC Submits Comments to CMS on Proposed “Sunshine” Rule

February 24, 2012—AAMC Feb. 17 submitted a letter to the Centers for Medicare and Medicaid Services (CMS) in response to a request for comments on the proposed rule concerning Transparency Reports and Reporting of Physician Ownership or Investment Interests.  The request was published in the Federal Register Dec. 19, 2011.  Implementing a provision of the Affordable Care Act (P.L. 111-148 and P.L. 111-152), the proposed rule requires manufacturers of drugs, devices, biological, and medical supplies to report annually to CMS any payments or transfers of value made to physicians and teaching hospitals. CMS will publish these reported payments on a public database.

CMS requested comment on a number of key issues including the form of each payment or transfer of value, the categories assigned to reported payments, and the process for reviewing the reported information and resolving any disputes regarding the value of a reported payment.  The AAMC urges CMS to clarify certain provisions and revise the proposed rule to lessen the burden on physicians and teaching hospitals when reviewing and responding to reported payments.  The association also recommends that CMS narrow the proposed reporting of indirect payments to address unintended consequences that could result in misleading information being reported.


Heather Pierce, JD, MPH
Sr. Director, Science Policy & Regulatory Counsel
Telephone: 202-478-9926


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806