The Sunshine Act--or what the Centers for Medicare and Medicaid Services now calls the National Physician Payment Transparency or "Open Payments" program--is upon us and will have an impact on radiologists and, in particular, practice managers.
The American College of Radiology is warning its members who interact with medical device and pharmaceutical manufacturers that they should start tracking certain kinds of financial relationships they have with members of those industries.
As the title of the law suggests, the idea is to bring transparency to financial relationships between physicians and vendors. It requires, among other things, that manufacturers of medical devices, supplies and drugs collect and report any payments made to physicians greater than $10, such as consulting fees, travel, research, meals, etc.
The law requires manufacturers to begin collecting this tracking this payment information on August 1 of this year and to submit the 2013 data by March 31, 2014. At some point in 2014 the information in the database will be made available to the public.
In an article in Diagnostic Imaging Nogah Maramati, M.D., professor of clinical radiology at Albert Einstein College of Medicine (and who wrote an article about the act earlier this year for the Journal of the American College of Radiology), said that much of the work involved in making sure physicians are adhering to the act will be done by business managers and assistants--those that set up meetings with industry representatives.
In the same article Bob Still, a practice administrator at MRI Group in Lancaster, Penn., said that while manufacturers are responsible for reporting this information, physicians should take the time the time to review this information because their name goes in the database--and their reputations could be at stake.
He suggested that practices make tracking this information part of their compliance program, perhaps reviewing payments quarterly. But, he added, radiologists need to take some responsibility as well. "[They] need to be cognizant that most of that is traced by physician and not practice," he said.
The American Medical Association has published a toolkit to help physicians educate themselves about the law and help them ensure the accuracy of their financial data.
To learn more:
- see the notice from the American College of Radiology
- read the article in Diagnostic Imaging
- see the article in the Journal of the American College of Radiology
- check out the AMA toolkit