Comments from Pharmaceutical Research and Manufacturers of America on Open Payments Definitions

Enacted via the U.S. Affordable Care Act, the Physician Payments Sunshine Act requires that pharmaceutical companies and medical device companies in the U.S. report "transfers of value" (or payments) they distribute to physicians on an annual basis. These payments are published in a public database, enabling patients to look up their doctors and determine how much they had been paid via manufacturuers. The original intention was to track conflicts of interest in prescribing in the U.S. 

Prior to the implementation of the final reporting standards, a number of stakeholder submitted comments to the U.S. Center for Medicare and Medicaid Services - the federal agency responsible for stewarding the data reporting program. The website here links to comments from the Pharmaceutical Research and Manufacturers of America, which is a trade group representing the pharmaceutical industry in the U.S. Their comments outline a number of reservations regarding CMS's proposed definitions for an "applicable manufacturer" - the individuals required to report to this program.