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Clarifying upcoming reporting deadlines in DC, MA


As your company prepares to file its transparency reports in advance of this week's deadlines for Massachusetts and the District of Columbia, we thought it would be helpful to clarify exactly when the reports are due.  

WV disclosure law repealed, but is this year's report still required?


On March 24, West Virginia Governor Earl Ray Tomblin signed into law a repeal of the West Virginia statute that included the prescription drug advertising expense report required in §16-29H-8.  Additional information on the law can be found on the Policymed website.  One big question that remains, however, is whether or not the disclosure report due next week (April 1) is still required.  

French “Sunshine” Decree Published

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The French “Sunshine” Decree (here, a regulation) was published in final today, May 22, 2013.  Click here for more information.  We are reviewing a Google-translated copy (i.e., not great, but the fastest translater I'm aware of!) and will have further information on this interesting development, but have the following to share now:

Highlights of 2013 Aggregate Spend State Legislative Activity


Written by: Marc Adler, Esq., Director of Compliance Consulting

While I am sure your organization has been primarily focused on efforts to comply with the federal "Sunshine" law as well as filing the Vermont and/or West Virginia disclosure reports, our Compliance Services team wanted to share with you some of the noteworthy aggregate spend bills proposed in 2013 (so far).


The Massachusetts legislature has proposed amendments that focus on the new quarterly, "non-CME educational presentation" reports enacted into law last year.  Unfortunately for the life sciences industry, however, just as companies were starting to think that the Massachusetts requirements would become less strict, the proposed changes would impose additional burden.  Specifically, bills in the Massachusetts House and Senate, which are now under consideration by the Joint Committee on Public Health, contain the following proposed changes:  

Vermont Sunshine Law Update: AG's Office Announces Offer of Amnesty


Written by: Vahan Minassian, Esq., Compliance Analyst

The Vermont Attorney General’s Office announced an offer of amnesty, expiring October 1, 2012, to manufacturers of medical devices and biologics who failed to comply with reporting obligations under the Prescribed Products Gift Ban and Disclosure Law (“Gift Ban and Disclosure Law”). In other words, under certain conditions, the Attorney General will not seek penalties on manufacturers who failed to comply with reporting requirements under the Gift Ban and Disclosure Law. The Attorney General anticipates, however, that it will require manufacturers to disclose “some aggregate information related to the [unreported] activity” at a later date. The offer of amnesty is limited to the following circumstances:  

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