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PPSA: An Implementation Timeline of Uncertainly and Confusion

December 17, 2014

The Physician Payment Sunshine Act, or PPSA, has been an ongoing source of confusion and controversy for all stakeholders in the CME community. Global has worked with a number of these stakeholders including The CME Coalition, medical education companies, as well as pharmaceutical and medical device companies in an effort to clarify much of the confusion throughout the past two years.

Initial Ruling

In April of 2013 the Center for Medicare and Medicaid Services (CMS) issued its final rule that distinguished between direct payments from pharmaceutical companies to physicians, and other indirect grant payments made through educational grants. The industry as a whole took a bit of time to understand and implement best practices for complying with the ruling, and Global released a video blog that answered many of the questions and common misinterpretations.

CMS revises ruling

Less than a year after a decision was made on the final rule, CMS proposed to eliminate the CME exclusion entirely. Global again released a blog explaining why this was idea was short sighted and might potentially cause larger issues, and a push was made by the entire CME community to keep this exemption in place. CMS accepted comments until September of 2014 regarding whether to keep the CME exemption in place within the final ruling.

Uncertainty remains around final ruling

The hard work and effort put forth by the community paid off, and in November of 2014 the CMS issued a final rule that redefined the PPSA reporting rules and criteria for payments that need to be reported. While there still is a bit of confusion around some of the wording in the ruling, Global has taken the initiative to explain and clarify in a recent blog post As we move into 2015 and prepare for the implementation of the final ruling, we at Global will continue to monitor and assess any pertinent information that might impact you as a CME stakeholder. If you have any questions related to the PPSA, or any CME questions in general, please reach out to us at any time.