Physician Transparency for Prescribed Products (aka Sunshine Act)

This is a post about my own personal opinion and knowledge and what I have learned working with physicians. It is not necessarily a proper representation of my employer.

6613516979_61ef5d0991_oWith all the terms and policies floating around (ACA, PCMH, NCQA, ACCME), it’s nice to finally get one with a full and simple name. The Sunshine Act. Also known as Physician Payment Sunshine Act or Physician Financial Transparency Reports, is a part of the Affordable Care Act. But what does that mean and how does it effect you as an organization, physician, or patient?


Organizations in this care are specifically manufacturers and group purchasing organizations for medical supplies, pharmaceuticals, and any medical item that requires prior prescription or recommendation from a physician. This does not effect consumer product companies. 

If your organization represents a prescribed or recommended medical product, then your company should have begun reporting financial information to the Centers for Medicare and Medicaid Services (CMS) on the physicians you interact with. This includes gifts with financial value, but may not include some patient education resources. Organizations also do not have a report when they fund a Continuing Medical Education (CME) session, but must follow the ACCME Standards for Commercial Support. 


Physicians do not have to report these gifts in most cases, but will have opportunity to review and approve in July- August 2014. Physicians will need to sign up in January 2014 to get reminders to review. Physicians have to review by law. They have a minimum of 45 days to review. Physicians can dispute for up to 2 years.

Medical students, residents, nurse practitioners, and PAs are not included in this recording requirement.


Beginning in October 2014, you will be able to see information about your physician that may represent a bias in their treatment options or just as likely, it may represent their expertise within the physician community if they have lead a research study or are paid to be a speaker on certain topics.

Most of this information came from the Physician Financial Transparency Reports (Sunshine Act) Summary webinar. More information and this webinar can be found at


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