No. The CMS recently updated an FAQ to provide more clarification on this topic, and in many circumstances reporting is not required. The entire FAQ can be viewed here.
As a CME stakeholder or pharmaceutical manufacturer, do I have to report transfer of value in every situation?
Weekly Compliance Tip
How do we mitigate a planner’s financial relationships with ineligible companies?
Institute a process and documentation to demonstrate that the planning team … More >
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