Sunshine Act Reporting Exclusion Applies to Independent CME

In April the Centers for Medicare & Medicaid Services (CMS) issued new frequently asked questions regarding when continuing medical education (CME) would be reportable in the Open Payments System. The new guidance states reporting is not triggered unless the manufacturer requires, instructs, directs, or otherwise causes the third party to provide the payment or transfer of value, in whole or in part, to a covered recipient.  

The American Medical Association notes this is not a free pass. The exclusion applies only to independent CME. AMA strongly encourages medical societies to review their planning processes to ensure adherence to standards for independence. At a minimum, meeting funding should in no way influence program development and other aspects of the planning process, AMA says. AMA encourages maintaining up-to-date conflict-of-interest disclosures from all involved in the planning process.   

For additional guidance, review AMA's policy statement, Financial Relationship with Industry in Continuing Medical Education.  

Action, May 1, 2015

Last Updated On

May 12, 2016

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