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
Is it necessary to collect financial disclosures from our staff annually?
Accredited providers must collect disclosures for all individuals in control… More >
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