Today, the CME Coalition published a comprehensive Sunshine Act Compliance Guidebook to provide commercial supporters, CME providers, and CME event participants with clear rules for ensuring compliance with the Sunshine Act. This Guide is based upon a thorough review of the most recent CMS guidance, regarding the requirements for determining which payments may be exempt from the mandated Sunshine reporting rules, and when others must be reported. Further, this summary is based on authorities existing as of the date of this document, and any recommendations herein are subject to further guidance from CMS. The guidebook is available by way of the link provided above.
UPDATE: On September 23, 2013, the Coalition published a Frequently Asked Questions (FAQs) supplement to its Sunshine Act Compliance Guide. This document includes important answers and citations to regulation intended to answer a number of questions, including: how to handle attendee meals, treatment of various accrediting bodies/rules, and treatment of educational materials.