Medical device manufacturers are just days away from being required to track and report financial arrangements with health care providers, as required by the Physician Payment Sunshine Act (the “Sunshine Act”). (Read the final rule.) Beginning August 1, 2013, most device manufacturers will be required to annually collect data regarding payments and transfers of value provided to physicians and teaching hospitals. Despite this impending implementation date, much uncertainty still remains regarding the scope of payments and transfers of value that must be reported and the methodology for valuing those payments and transfers of value. Companies are encouraged to review their policies, procedures, and systems for complying with the Sunshine Act to ensure that they can satisfy their reporting requirements. For more information about Sunshine-related issues facing device companies, please see this client alert.