Industry-supported fellowships and the "Sunshine" Act.
A number of clinical fellowship programs at Partners hospitals receive industry funding to help off-set costs associated with the program. This type of funding helps the hospitals within the Partners HealthCare System to provide the highest quality training opportunities for fellows. Partners has implemented policies to ensure that a fellow’s training experience is designed exclusively by physician educators and not inappropriately influenced by industry support. For instance, all industry support to a clinical fellowship program is vetted by the Partners Education Review Board (“ERB”), which requires that each industry-supported program have at least two industry supporters and that the support be directed to the departmental program, not the individual trainee. For more information about these policies, please contact the Office of Interaction with Industry.
Under Federal law, the Physician Payments Sunshine Act (“Sunshine”), companies are required to report any direct and indirect payments and transfers of value to physicians and teaching hospitals. Any industry support provided to a fellowship program will likely be reported on a publicly-accessible website by the Centers for Medicare & Medicaid Services (CMS) in two ways. First, the payment will be reported as a direct payment from the company to the hospital. In addition, under the “indirect payments” provision of Sunshine, we anticipate that industry will likely report these funds as indirect payments from the company to any physicians or fellows participating in the program. Our expectation is that companies may report these indirect payments divided among the total number of fellows in each program. Therefore, if you participate in a fellowship that receives or intends to receive industry support, you should anticipate that it is likely you will be reported as having received an indirect payment from the companies supporting your fellowship—even though industry payments are made to your teaching institution and not to you directly. If you are in a fellowship that intends to receive industry support, but is unable to secure such funding, you will not be reported to CMS as receiving an indirect payment from the company.
For indirect payments, companies must provide specific information to CMS, including the physician’s name and NPI number. Since the companies are required to provide this information under Sunshine, Partners has to provide companies with the names and NPI numbers of fellows in industry-supported fellowship programs. However, before providing this information to the companies, we verify that the companies will not share or use such information for the purposes of sales and/or marketing.
If you have any questions about the Sunshine Act and how it could affect you, please visit http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-payment-Transparency-Program/index.html, contact the Program Director of the fellowship to which you are applying, or contact the Office for Interactions with Industry.
This page was updated on 3/9/18.