The requirement to record payments and transfers of anything of value to dentists has been delayed until HHS publishes a final rule on the Physician Payment Sunshine provisions of the Patient Protection Affordable Care Act (PPACA). The proposed rule was published on December 19th in the Federal Register. You can view the proposed rule.

While we await the final rule in early spring, the following summary of the law is helpful as an overview.

The new law requires that Companies must begin keeping records next year, however, the first reports from companies won’t be due until 2013. The provision creates new reporting requirements for drug, biologic and medical device companies to document and report all payments and transfers of value to dentists, physicians and teaching hospitals.

"Every DTA member that provides anything of value to a dentist must develop a mechanism to track those transfers, but now companies can wait for the final rule before they begin collecting data," said DTA CEO Gary Price.

There is a minimum value of $10 per payment or $100 per year on what has to be reported. The provision requires companies to report direct payments of honoraria, food, travel and compensation for serving as a faculty member. There is no requirement to report payments made through third parties where the manufacturer does not know the identity of the dentist or physician learners.

Information that must be submitted by manufactures includes:

• The name and business address of the covered recipient.
• The National Provider Identifier (NPI), if the recipient is a physician. ^**
• The amount of the payment or other transfer of value.
• The dates on which the payment or other transfer of value was provided to the covered recipient.
• The name of the product to which the payment or other transfer of value relates (if the payment is related to a specific product).
• A description of the nature of the payment or other transfer of value.
• A description of the form of the payment or other transfer of value.
• Any other categories of information regarding the payment or other transfer of value the Department of Health and Human Services deems appropriate.

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Proposed Rule

NPPES NPI Registry