Frequently Asked Questions

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Are distributions to physician owners of LLC units in a physician owned distributor (POD) considered reportable payments or other transfers of value or are they incidents of ownership and not considered reportable?

If a POD falls within the definition of an applicable manufacturer or applicable group purchasing organization (or both), then they must report distributions provided to physician owners of LLC units in the POD for purposes of Open Payments.

Key words: Open Payments, Sunshine Act

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