The proposed rule for the Physician Payment Sunshine Act is a crucial step toward illuminating physician-industry financial ties. But patient advocacy groups and professional medical associations producing CME, though they may not be “covered recipients” under the law, could be impacted, observes Tom Sullivan, president of Rockpointe.

If such groups get a reportable payment from a manufacturer and use any portion of it or transfer of value toward a covered recipient—a physician or teaching hospital—if “the applicable manufacturer is ‘aware’ of the covered recipient’s identity, the manufacturer is required to report how much your organization or group…paid.”