According to the Centers for Medicare and Medicaid, data collection by manufactures will not be required until 2013. See their post bellow:
On December 19, 2011, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule implementing the Physician Payments Sunshine Act, which was included as section 6002 of the Affordable Care Act of 2010. This provision will provide important transparency in requiring reporting of payments or gifts to physicians, and physician ownership and investment interests. During the 60 day comment period, CMS received over 300 comments from a wide range of stakeholders.
CMS is committed to addressing the valuable input received during the comment period, and to ensuring the accuracy of the data collected. In order to provide time for organizations to prepare for data submission and to sufficiently address the important input we received during the rulemaking process, CMS will not require data collection by applicable manufacturers and applicable group purchasing organizations before January 1, 2013.
CMS intends to release the final rule later this year. This timing will provide CMS with additional time to address operational and implementation issues in a thoughtful manner, and the ability to ensure the accuracy of the data that is collected.
Given the complexity of the rule, we think this is a reasonable position for CMS. It shows that they are thoughtfully considering the input they received and taking implementation issues to heart. CMS should be commended for this action.