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Preparing for the Sunshine Act

September 03, 2013

The Physician Payment Sunshine Act (PPSA) went into effect on August 1, 2013, and with it comes a few notable changes to CME. As part of our continued efforts in research and funder development within the CME industry, Global has taken the initiative in analyzing the complexities and ambiguity of the new guidelines. In April 2013, Global released a video blog clarifying what payments are now reportable, as well as suggestions for reporting meals and listing faculty names in grant requests. Now that the August 1st deadline has arrived, we want to ensure that each of our partners fully understands the provisions of the act and the effect that they have on CME accredited programs. Over the past few weeks, we have been working closely with funders to understand their new policy and regulation changes in response to the PPSA. We have had a number of funders respond to our inquiries, and we will continue to hold discussions over the coming weeks. In the meantime, we encourage you to review our initial policy updates listed below when planning your CME event. We will continue to distribute policies and guidelines to our partners as they are released. While many providers have not released their PPSA guidelines or policy changes, we want to remind our partners that while planning your CME event there are three important guidelines to follow to ensure that your CME activity meet the exemption criteria as laid out by the CMS:
  • The provider or event is accredited/certified by the ACCME, AAFP, ADA, AMA, or the AOA.
  • The manufacturer does not select the covered recipient speaker or provide the third party (CME provider) with a distinct, identifiable set of individuals to be considered as speakers for the CME program
  • The applicable manufacturer does not directly pay the covered recipient speaker

Preview of PPSA Funder Policy Updates Chart

Organization Name PPSA Policy Language Meals Permitted Meal Permission Requirements Policy release Date
Allergan Click here for full guidelines Yes Only box or buffet meals for attendees may be supported as food and beverage expense, and there will be no reporting requirements 07-31-2013
Boehringer Ingelheim No official policy language at this time Yes
BMS Click here for full guidelines Yes BMS funding may not be used towards food and/or beverages at an activity with less than 100 attendees. For activities with more than 100 attendees funding may be used for buffet meals only 07-31-2013
Celgene No official policy language at this time Yes “Meals provided to attendees in conjunction with an accredited program should be modest and in a manner conducive to a group educational environment (e.g., buffet).”
Mentor Click here for full guidelines No 07-29-2013
Pfizer Click here for full guidelines No “Pfizer grant funds will no longer support food or beverage in any capacity.” 08-02-2013
UCB Click here for full guidelines Yes Only box or buffet style meals may be presented to attendees 07-31-2013