The Federal Sunshine Act: A Practice Guide

By Christine N. Bradshaw and Elizabeth H. Kim

In the words of Justice Louis D. Brandeis, former Associate Justice on the Supreme Court of the United States, “Sunlight is said to be the best of disinfectants.”1 In that spirit, the federal Sunshine Act was created to ensure transparency in the financial relationships between the life sciences industry and certain healthcare professionals (HCPs) and organizations. It was introduced as part of the Patient Protection and Affordable Care Act (PPACA). The regulations implementing the law became final on April 9, 2013, and life sciences companies are scrambling to comply with the first report submission deadline, March 31, 2014.