On November 13, 2014, CMS published the 2015 Medicare Physician Fee Schedule (“MPFS”) finalizing the following changes to the Sunshine Open Payments regulations.  The MPFS:

  1. Deleted  the provision exempting certain payments to CME providers from the reporting requirements;
  2. Added  three new forms of payment designations;
  3. Made  the reporting of the marketed name of a covered

by Sarah K. Giesting, Wendy C. Goldstein, Kathleen A. Peterson, and Natasha F. Thoren

On December 14, 2011, the Centers for Medicare & Medicaid Services issued long-awaited proposed rules (“Proposed Rules”) related to the federal Physician Payment Sunshine Act applicable to pharmaceutical, medical device, biological and medical supply manufacturers and group purchasing