Written by Mark Gardner, DuVal & Partners on FDA.

CMS finally published a Proposed Rule for the Physician Payment Sunshine Act (the “Act”), which was passed last year.  The Proposed Rule was initially due by October 1, a deadline CMS missed.  All 121 pages of the Proposed Rule are located here:  https://s3.amazonaws.com/public-inspection.federalregister.gov/2011-32244.pdf.  We have attempted to break the Proposed Rule down to save you some time!  Please call us if you need help preparing for the new law.  Companies that fail to report are subject to fines ranging from $1000-10,000 per occurrence for unintentional conduct and $10,000-$100,000 for intentional conduct.