Federal Payment Sunshine Law: Implications for Manufacturers and Providers

Navigating the New Federal Mandate on Public Disclosure of Payments

Reporting requirement effective Jan. 1

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, December 6, 2011

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will provide guidance to legal or compliance advisors to manufacturers, physicians and teaching hospitals for navigating the Sunshine Law. The panel will offer practical strategies to ensure compliance with the new law and avoid costly mistakes or unexpected public disclosures.


The new Federal Payment Sunshine Law requires manufacturers of drugs, biologics, devices and medical supplies covered under Medicare, Medicaid and the Children’s Health Insurance Program to track payments and other transfers of value to physicians and teaching hospitals beginning January 1, 2012.

Manufacturers must implement policies, procedures and systems to ensure compliance with the Sunshine Law. Implementation is challenging and requires manufacturers to interpret and apply ambiguous requirements. Non-compliance may result in fines of up to $10,000 for inadvertent non-compliance and up to $100,000 for knowing non-compliance.

The Sunshine Law also has consequences for physicians and teaching hospitals receiving payments or other transfers of value. Physicians and teaching hospitals need to know what information will be disclosed and how that information will be presented. Government enforcement agencies may also scrutinize information to identify fraud and abuse or other concerns.

Listen as our authoritative panel, including a healthcare law attorney and compliance personnel, discusses the new Federal Payment Sunshine Law and its implications for manufacturers, physicians and teaching hospitals. The panel will offer practical strategies to ensure compliance with the new law and avoid costly mistakes or unexpected disclosures.



  1. Overview of Sunshine Law requirements
    1. Who must report
    2. What must be reported
    3. Exclusions from reporting
    4. Implications of public disclosure
  2. Meeting general compliance challenges
    1. Identifying transfers of value to physicians and teaching hospitals, particularly when transfer is made to a third party other than a physician or teaching hospital
    2. Scope of exemptions from reporting
    3. Identifying and tracking transfers of value
    4. Reconciling different obligations under state and federal laws
  3. Compliance challenges for specific industries
    1. Pharmaceutical companies
    2. Medical device companies
  4. Implications and best practice responses for physicians and teaching hospitals


The panel will review these and other key questions:

  • What are the key requirements of the new Federal Payment Sunshine Law?
  • Which categories of payments or transfers are exempt from the law's requirements?
  • What steps should manufacturers and their counsel take immediately to ensure compliance with the new law?
  • What steps should physicians, teaching hospitals and their counsel take to minimize increased liability exposure resulting from the new public disclosure requirements?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Eve M. Brunts
Eve M. Brunts

Ropes & Gray

She regularly advises clients on Medicare and Medicaid coverage, claims and payment requirements for a variety of...  |  Read More

Bill McKenzie, CPA
Bill McKenzie, CPA
Health Care Compliance Officer
DePuy Spine, Inc., a Johnson & Johnson Company
Conner Childers
Conner Childers
Director for Global Healthcare Compliance Operations  

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