RxVantage & the Sunshine Act
Helping healthcare providers and medical companies track and report activity and remain compliant.
The Sunshine Act, which is also referred to as Open Payments, affects most medical practices. The overarching goal is to shed light on the relationship between industry (pharmaceutical companies and other medical vendors) and the individual medical practices. One of the most practical first steps in navigating the Sunshine Act is to implement a rules-based system that manages how your practice interacts with representatives, and to also keep track of these interactions. RxVantage does this very well.
Track everything easily
RxVantage captures and reports data for recording exposure to Sunshine Act thresholds. For example, the platform will capture, record and track the dollar value of meals served during pharmaceutical presentations. With the data organized by the RxVantage platform, medical offices and manufacturers have a common data set to report to CMS.
Frequently Asked Questions
What is the Sunshine Act?
The Physician Payments Sunshine Act (Sunshine Act) which is part of the Affordable Care Act (ACA), requires manufacturers to report payments and “transfers of value” made directly to physicians and teaching hospitals. Manufacturers are required to describe how the recipient received the payment such as cash or cash equivalent, in-kind items or services, or stock, stock options, or any other ownership interest, dividend, profit, or other return on investment. In addition, manufacturers must specify the nature of the payment or transfer of value that are made indirectly to a physician or that are made to a third party as requested by a physician or designated as being made on behalf of the physician.
What size "payments" must be reported?
If the value of an individual payment or transfer is less than $10 per physician and the total annual gift is less than $100, it does not have to be reported. If an individual physician receives a single payment in excess of $10 or exceeds $100 in payments per year from an individual manufacturer, it must be reported. For example, if a physician receives a single $5 journal reprint in a given year, it will not be reported. If they receive 21 $5 journal reprints in a year (21x$5=$105), all 21 transfers will be reported.
Are Sales Rep interactions covered by the Sunshine Act?
Yes. When representatives deliver items of value that must be reported, they will record the nature and value of the item(s) as well as the physician(s) to whome the items were transferred. They will also record the name of the related drug, device, biologic, or supply (i.e. the product that the rep was discussing).
How does the Sunshine Act affect lunch & learns?
When a rep brings a meal as part of lunchtime educational sessions, the total cost will be divided by the total number of people (physicians and staff) who partake in the lunch. For example, if a rep brings a $125 lunch for 3 physicians and 7 staff members, $12.50 ($125/10) will be reported for each physician. If the per person cost of the lunch is less than $10, it will not be reported (unless the total annual value of transfers to an individual physician exceeds $100).
Do patient samples need to be reported under the Sunshine Act?
No. Samples, vouchers and coupons are not considered payments or transfer of value to physicians, nor are any educational materials that directly benefit patients or are intended for patient use.
Does the Sunshine Act cover ownership interests?
Yes. Manufacturers as well as GPOs are required to report on ownership interests held by physicians and their immediate family members. The transparency report must include the dollar amount invested, the value and the terms of ownership or investment interest, and any payment provided to a physician owner or investor. However, there are certain ownership interests, such as securities, which may be purchased on terms generally available to the public and which are listed on a stock exchange in which quotations are published on a daily basis, which are not reportable ownership interests.
Learn more about the Sunshine Act
Decoding the Sunshine Act
Watch this recorded webinar from RxVantage to understand exactly how the regulation affects the office-rep relationship.
Sunshine Act Best Practices
Learn how medical practices have adapted to the Sunshine Act with minimal disruption.
Center for Medicare & MediCaid Systems
Policy and Medicine
American Academy of Family Physicians
Article the dissects the background of the regulation and potential >
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