On November 27, the Centers for Medicare & Medicaid Services sent its long-awaited final version of the Physician Payment Sunshine Act regulations to the Office of Management and Budget for review. With this development, the final Physician Payment Sunshine Act rules will likely be published within the next 90 days.

While the exact parameters of the rule are unknown, affected manufacturers should start planning for implementation, if they have not done so already. We recommend that manufacturers work from the statute and the proposed regulations in order to respond quickly once the final regulations are issued.

By the government's estimate, manufacturers should dedicate significant resources to compliance in upcoming budgets.