Transfer of Value Reporting

What is the Sunshine Act?

The Physician Payments Sunshine Act is a federal transparency law requiring pharmaceutical and medical device manufacturers to report payments and transfers of value to healthcare providers.

Types of Transfers of Value

The Sunshine Act requires reporting of various value transfers:

Reporting Thresholds

Federal (Sunshine Act)

• Individual payments $10 or more: Must be reported if annual aggregate to one HCP exceeds $100
• Payments under $10: Not reported unless aggregate exceeds $100
• No minimum for ownership/investment interests: All must be reported

State-Specific Requirements

Some states have additional or different thresholds:

Configuring TOV Tracking in MyEventsAI

Data Collected for Each Transfer

MyEventsAI captures all required fields for CMS Open Payments submission:

• HCP Information: Name, NPI, specialty, address, state license number
• Payment Details: Amount, date, payment type, nature of payment
• Product Information: Associated drugs or devices (if applicable)
• Event Context: Event name, date, location, educational purpose
• Sponsoring Entity: Manufacturer name, address, tax ID
• Attestation: Signed acknowledgment of value receipt

Meal Value Calculation

Accurate meal value reporting is critical. Include these costs:

TOV Reports & Exports

MyEventsAI provides pre-formatted reports for compliance teams:

Submission Deadlines

Federal (CMS Open Payments)

• Registration: By December 31st of reporting year
• Data Submission: By March 31st of following year (90 days after year-end)
• Review Period: 45 days for HCPs to dispute/correct
• Publication: June 30th - data becomes public on CMS website

State Deadlines (Examples)

• Vermont: April 1st of following year
• Massachusetts: July 1st of following year
• Minnesota: May 1st of following year

Best Practices

Common Compliance Issues

Underreporting Meal Values

Problem: Forgetting to include tax, tip, or venue costs

Solution: Use actual invoices/receipts, divide total by attendee count

Aggregation Errors

Problem: Not combining multiple small transfers to same HCP over year

Solution: MyEventsAI auto-aggregates by HCP NPI and alerts when threshold reached

Invalid NPIs

Problem: Submitting deactivated, retired, or incorrect NPIs

Solution: Enable NPI verification during registration, validate before export

Resources

• CMS Open Payments - Official reporting system
• Open Payments Database - Public search tool
• Data Submission Specifications - Technical format guide