(202) 688 0222
CME Coalition
  • Home
  • About
    • Members
    • Staff
    • FAQ
  • Membership
    • What We Do
    • Prospectus
    • Join the Coalition
    • Contact
  • Issues
    • The Value of CME
    • COVID-19
    • Quality Improvement CME
    • Shared Decision-Making
    • Open Payments
    • CME vs. Marketing
  • News
    • Press Releases
    • CME in the News
  • Resources
  • Contact

CME COALITION SUBMITS COMMENTS TO CMS REGARDING PROPOSAL TO ELIMINATE SUNSHINE ACT Exemption

8/29/2014

 
The CME Coalition has submitted public comments to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed change to the Sunshine Act’s current exemption for reporting transfers of value that are affiliated with accredited CME provider organizations to the Open Payments Database.  In its submission, the Coalition embraces the preamble of CMS’s proposed rule, that the criteria for determining Sunshine-exempt continuing education should be expanded. However, the Coalition’s analysis of the proposed rule’s actual language suggests that rather than expanding the exemption beyond the originally designated “five accrediting bodies,” the proposal could instead require additional reporting for both speakers and attendees at CME events. The resulting elimination of the CME exemption could be devastating for the practice of CME. 
In its place, the Coalition suggests specific language that it believes could meet CMS’s stated objective of designing a policy whereby “if an applicable manufacturer conveys ‘full discretion’ to the continuing education provider, those payments [should be] outside the scope of the rule,” and thus not reportable.
CME Coalition Sunshine Act Comments
File Size: 473 kb
File Type: pdf
Download File


Comments are closed.

    Categories

    All
    Code Of Conduct
    Commercial Logo Use
    MACRA
    Privacy Policies
    REMS
    Sunshine Act
    Webinars

About

Mission
Government Affairs
Issues
Members
Staff
FAQ

Membership

Why Join
Testimonials
Join the Coalition

Resources

Sunshine Act
REMS
Commercial Logo Use
Privacy Policies
Code of Conduct

Newsroom

Press Releases
CME in the News
Blog
Picture
Copyright © 2014 CME Coalition | 1720 Eye St. NW, Washington DC | clamond@thornrun.com