The Physician Payment Sunshine Act (PPSA)
The Physician Payments Sunshine Act (PPSA)
We are committed to the highest standards of integrity and ethics. We have long supported a nationally standardized approach to make the financial relationship between the healthcare industry and healthcare professionals more transparent.
Enacted by Congress in 2010, the Physician Payments Sunshine Act, commonly known as the Sunshine Act or Open Payments, is part of the Patient Protection and Affordable Care Act of 2010. The reporting system is administered by the Centers for Medicare & Medicaid Services (CMS).
Collaboration with some of the country’s foremost medical experts ensure our medicines meet the needs of patients and help drive peer-to-peer education.
Guided by the highest ethical standards, including company policy and the PhRMA Code on Interactions with Health Care Professionals, we appropriately compensate U.S.-licensed physicians and clinical trial researchers for the time, expertise and services they provide to conduct industry-sponsored research or educate their peers about medicines, which advance clinical knowledge and ultimately benefit patients struggling with serious diseases.
The following disclosures are required under the Sunshine Act:
- Physician name, primary business address, specialty, National Provider Identifier (NPI) number, and a state license number. U.S.-licensed physicians may be contacted to verify or provide their NPI number if it is not listed at the time of reporting.
- Amount, date, nature of payment (consulting fee, food, grant, etc.), and form of the payment or other transfer of value (cash, in-kind item, stock, dividend)
- Any covered products related to the "payment or other transfers of value" (POTV)
Open Payments defines Research as a “systematic investigation designed to develop or contribute to generalizable knowledge related broadly to public health, including behavioral and social sciences research, pre-clinical research and FDA clinical trials for Phases I through IV, as well as investigator-sponsored research.”
A written agreement/contract must also be in place between the manufacturer and the Covered Recipient.
Examples of Research "payment or other transfers of value" (POTV)
- Costs associated with patient care including diagnostics, exams, laboratory expenses, and time spent by the healthcare professional treating the patient
- In-kind items such as provision of study drugs, devices, biologicals, and medical supplies
A list of our payment categories is available on the CMS Website.
If you have a question about transactions reported by Bristol Myers Squibb, contact our Transparency Hotline at 877-701-4572, or email your inquiries to mg-transparency_bms@bms.com
Who is a Covered Recipient?
Our collaboration with medical professionals has fueled innovative medicines that help patients prevail over serious diseases, and we believe in fair compensation for the work they do.
In addition to CMS-teaching hospitals, the following U.S.-licensed physicians are also included in our report.
- Doctor of Medicine
- Doctor of Osteopathy
- Licensed Chiropractor
- Doctor of Dental Surgery
- Doctor of Dentistry
- Doctor of Optometry
- Doctor of Podiatry
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists & Anesthesiologist assistants
- Certified nurse-midwives
The following medical professionals are not included:
- Resident
- Pharmacist
- Nurse
- Social Worker
- Case manager
- Office manager
Please note state reporting requirements may differ.
What types of “payment or other transfers of value” (POTV) are we required to report?
- Clinical reprints and publications
- Fees paid for speaker and consulting services
- Travel, lodging, and out-of-pocket expenses for speaker and consulting services
- Food and beverages provided in-office or out-of-office
- Grants (also reportable when provided to CMS-teaching hospitals)
- Research payments (also reportable when provided to CMS-teaching hospitals)
What Items are excluded from reporting?
- Payments or other transfers of value that are less than the annual threshold, unless the total aggregate amount of all items exceeds the annual maximum amount during the reporting period
- Small, incidental items (including food and educational items) valued less than the annual threshold that are provided at large-scale medical conferences
- Education materials and items which directly benefit patients or are intended for patient use (e.g., anatomical model)
- Co-pay cards
- Discounts/Rebates
- Samples/Vouchers
Please note Open Payments reporting thresholds are based on the consumer index report and are subject to change annually.