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Sunshine Act

The Physician Payment Sunshine Act (Sunshine Act) requires applicable manufacturers of drugs, devices, biologicals, or medical supplies to report transfers of value to health care providers to the Centers for Medicare and Medicaid Services (CMS). The Act is a provision of the Patient Protection and Affordable Care Act that establishes a system and structure that monitors and publishes such forms of health care providers/professionals (HCP's) and industry interactions.  According to the CMS, the aim of this greater transparency is to help reduce the conflict-of-interest situations as a result of relationships between HCP's and the companies that manufacture and sell the products they use.

Commencing August 1, 2013, manufacturers are required to record and publically report these transfers of value.  Information collected, as required by the Sunshine Act, will first be reported to CMS by March 2014.  Manufacturers will be responsible to report this information annually thereafter.

Once the information has been submitted to CMS, HCP's shall be provided a 45-day review period in which they may contest any part of the submission for which they disagree. Following this review period, CMS will post this information (transfers of value) on a publically available website and searchable database based in part upon the HCP's National Provider Identifier (NPI) or State License Number.

To ensure the accuracy of the data submitted, HCP's are encouraged to validate the accuracy of their National Provider Identifier (NPI) number at the NPPES website at https://nppes.cms.hhs.gov.  HCP's without the NPI number can go to this website as well to obtain an NPI number.

Geistlich recognizes and adheres to the requirements outlined within the US Federal Sunshine Act.

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