Issue link: https://viewer.e-digitaledition.com/i/122157
who holds an ownership or investment interest in the manufacturer There are special rules for the reporting of payments for research, continuing educational programs, and food and beverages. There are also several exceptions to the reporting requirements. Both manufacturers and group purchasing organizations (GPOs), which include physician-owned distributorships, must report all ownership and investment interests in the manufacturer or GPO held by a physician or an immediate family member of a physician, including: + Physician name, address, specialty, NPI and state license number(s) + Dollar amount invested by each physician/immediate family member + Value and terms of each ownership or investment interest information will be made public as submitted by the manufacturer, but marked disputed. Once resolved, changes will not be made until the next annual report. Before you accept anything of value from a manufacturer or invest in a manufacturer or GPO, you should evaluate the associated risks. And, if you decide to enter into any such arrangement, you should review and timely submit corrections to CMS regarding the information reported about you. Cassia M. Ysaguirre is a member of the Health Law Practice Unit in the San Antonio office of Strasburger Price Oppenheimer Blend. Collectively, the group has 67 years of experience representing corporate, health care and life sciences clients. You can reach Ysaguirre at (210) 250-6171. I Reference The term "manufacturer" generally includes any entity that is operating in the United States and that is engaged in the production, preparation, propagation, compounding or conversion of a covered drug, device, biological or medical supply, but not including distributors or wholesalers (including repackagers, relabelers and kit assemblers) that do not hold title to any covered drug, device, biological or medical supply. you're thinking: Supplementing income by offering ancillary services, reimbursement cuts from payors and shrinking revenues + Direct and indirect payments or others transfers of value provided to a physicia n holding a n ow nership or investment interest. There is no opportunity for physicians to opt-out of the reporting requirement. If a physician does not want to be included on the CMS website, he or she must refuse all payments and transfers of value from manufacturers and decline all investment oppor t u n it ies in ma nu fac t u rers and GPOs. Dispute Resolution Process The determination of value ascribed to various transfers of value to physicians can be complicated and may allow some discretion on the part of manufacturers. Thus, a physician might erroneously be identified as the recipient of a payment or other transfer of value. In light of this risk, the final rule requires that physicians be given the opportunity to review and submit corrections to reported information during a 45-day period prior to publication. Physicians will need to register on the CMS website in order to review reports prior to publication. If disputes are not resolved by the end of the 15-day period following the 45 -d ay rev iew per iod, repor ted we're thinking: Jim P. Rice, CPA jprice@ssacpa.com Jeff Jackson, CPA Tax implications & options for providing ancillary services, Practice assessment, Revenue enhancement opportunities jbj@ssacpa.com Bennett C. Allison, CPA cba@ssacpa.com When it's critical to you, Sol Schwartz & Associates Health Care Services helps you manage it. (210) 384 8000 www.ssacpa.com MDNEWS.COM I MD NEWS San Antonio | 19