Frequently Asked Questions

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Is a payment or other transfer of value provided by an applicable manufacturer’s distributor to a covered recipient considered a reportable indirect payment if the payment or other transfer of value is from the distributor’s own resources and the distributor does not hold title to any of the applicable manufacturer’s products?

Yes, if the applicable manufacturer requires, instructs, directs, or otherwise causes the distributor to provide the payment or transfer of value, in whole or in part, to a covered recipient or a physician owner or investor.

Key words: Open Payments, Sunshine Act

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