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

CME Providers Template Grant Language for the Sunshine Act

1/22/2016

 
In response to questions about the Sunshine Act 'reportability' for transfers of value related to the provision of accredited CME events, the CME Coalition has developed ‘template’ grant language for use in CME agreements between commercial supporters and providers.  The template included below, drafted with expert legal counsel from Arnold and Porter, includes language that tracks directly with CMS’ guidance indicating that supporters have not “directed, instructed or caused” the CME provider to pay specific covered recipients.
This template language is essential for two important reasons: (1) it provides written evidence confirming that grants do not generate reportable indirect payments; and (2) because of the concerns around potential over-reporting, it will help to document the fact that just because a commercial supporter may choose to report a CME-related payment to CMS, they are not inappropriately selecting a physician speaker or influencing the curriculum.  ​
CME Providers Template Language for the Sunshine Act
File Size: 45 kb
File Type: docx
Download File


Comments are closed.

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