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Sunshine Act


The Sunshine Act, a provision of The Patient Protection and Affordable Care Act, requires Bard and other medical device manufacturers, to collect and report all payments and other transfers of value given to physicians and teaching hospitals (“covered recipients”). Required data collection began on August 1, 2013. Annual reports of reportable transfers of value must be submitted to the Centers for Medicare & Medicaid Services (CMS) by March 31st of each year.

As required by the Sunshine Act, Bard will report the following transfers of value to CMS:

  • Meals paid for by Bard, including meals for which Bard reimburses a covered recipient.
    • The cost of a group meal will be divided equally among the attendees present during the meal.
  • Travel expenses (including airfare, lodging, ground transportation, etc.) paid for, or reimbursed, by Bard
  • Materials of commercial value provided to covered recipient (e.g., journal article reprints)
    • Any materials intended for direct patient education are not reportable.

Please note that physician attendees have the option to pay, or reimburse Bard, for training expenses.

Additional information on the Sunshine Act can be found on the Centers for Medicare & Medicaid Service’s Official Website for Open Payments (Physician Payments Sunshine Act) and on the American Medical Association’s Toolkit for Physician Financial Transparency Reports (Sunshine Act) pages. If you have any questions about Bard policies or reporting, please contact us at BPV.Sunshine@crbard.com.

BPV/BPAL/1016/0056