The following letter was sent to members of the Dental Trade Alliance on February 5, 2013...
The final rule on the Sunshine Act will be published on February 8, 2013 in the Federal Register. On February 1, the Centers for Medicare and Medicaid released an advance copy of the final rule. Click here to view the complete text of the final rule.
Several important points culled from the report:
** Data collection of gifts, meals, etc., for dentists begins August 1, 2013. Companies must report by March 31, 2014.
** Companies that sell a private label product sold under their brand name, manufactured by a separate manufacturer, are subject to the same rules of reporting and transparency.
** Companies that offer gifts, meals, etc., to dentists through a third party are required under the rules of transparency to report these gifts if they exceed the maximums established under the new rules.
** Foreign manufacturers with a U.S. location or represented by a separate party in the U.S. (or their U.S. representatives) are required to report gifts to dentists when exceeding the maximums allowed on a monthly or annual basis.
There is an enormous amount of information to sift through in this final report. DTA strongly encourages members to consult a tax professional or legal counsel to be sure your company is in compliance of the new “Sunshine Act” rules.
DTA plans to offer an updated “Sunshine Act” webinar in the coming weeks. Watch for the announcement and registration information.
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