As of August 1st, certain manufacturers of drugs, medical devices and biologicals are tracking their payments to physicians, as required by the Physician Payments Sunshine Act (Sunshine Act), which is part of the Affordable Care Act.  They will report payments and other items of value worth more than $10, as well as certain ownership interests held by physicians and immediate family members, to CMS annually.  Reporting may begin immediately, on a voluntary basis, and must begin by next January.  CMS will post the information, by physician, on a public, searchable website.  CMS published the final regulations implementing the Act on February 1, 2013, and we summarized the rule in an Alert dated February 18th.  We refer readers to that Alert for information on the “applicable manufacturers,” the definition of “covered products,” the form and nature of payments and other “transfers of value” that must be reported and reportable ownership and investment...