Cognitive Consulting and Sunshine Act Reporting

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Our clients can be assured that all work conducted in the US will abide by Sunshine Act reporting regulations. Please contact us to learn more about Sunshine Act nuances and what Cognitive is doing to stay compliant at info@cognitiveconsulting.com.

The Sunshine Act

With the intent to promote transparency in physician prescribing behavior, the Physician Payments Sunshine Act of 2010 created reporting requirements for certain payments made by healthcare manufacturers to prescribing physicians. As a result, all honoraria payments made to physicians throughout the course of studies in which the identities of physician respondents are known must be reported to the Centers for Medicare and Medicaid Services.

The Sunshine Act’s Impact on Market Research

Ultimately the Sunshine Act has had little impact on market research in the US as physician identities are almost always blinded.  Should the identity of a physician participating in market research be revealed to the pharmaceutical/medical device company sponsoring the research, payment information between the two parties must be reported under the Sunshine Act.   

Cognitive serves as a third-party liaison between the end-client and the physician, keeping the physician’s data private, even in single-blinded studies. If the end-client were to become aware of the physician’s identity during the course of a project, such as a physician revealing their name, Cognitive will report the information under the Sunshine Act, including the nature and amount of payment.