Takeda is committed to improving health for people worldwide through innovation in medicine. We recognize the important contributions of valuable insight, expertise and feedback that health care professionals (HCPs) provide to us in support of this mission.
The Patient Protection and Affordable Care Act Section 6002, commonly known as the Sunshine Act, requires that applicable manufacturers, like Takeda, track “transfers of value” provided to actively-licensed U.S. HCPs and teaching hospitals (“Covered Recipients”) and submit an annual report by March 31, 2016, covering transfers of value between January 1, 2015 and December 31, 2015.
In our experience it is helpful for HCPs to understand that there are two predominant reporting submission areas for transfers of value under the Sunshine Act: General Payments and Research. Takeda will report transfers of value into these areas based on the type of interaction conducted with HCPs. It is further helpful to understand that transfers of value with HCPs that do not meet the Sunshine Act definition of Research will be submitted as General Payments. We have found that a clear understanding of this delineation between Research and General Payments is very helpful to HCPs.
Transfers of value provided by, or on behalf of Takeda, including fees/reimbursable expenses that are individually greater than $10 or cumulatively greater than $100 will be reported and attributed to the Covered Recipient. It is important to note that transfers of value must show the Covered Recipient as well as the entity paid. For example, a clinical trial research payment to a teaching hospital would show the principal investigator and the hospital. Some additional examples of reportable transfers of value are listed below:
• Professional Services: Including payments for advisory boards, consulting services, or promotional speaking.
• Educational Materials: Including certain reference materials such as journal articles and textbooks
• Business Meals: Including Takeda provided or reimbursed meals provided in conjunction with professional services or recruiting
• Business Travel: Including Takeda provided or reimbursed amounts for transportation (e.g., airfare, hotel, taxi)
Takeda values working with HCPs and we believe such collaboration is critical to deliver better health and a brighter future to patients we serve.
Additional Information about Open Payments
To learn more about the Sunshine Act, please visit the Centers for Medicare and Medicaid Services (CMS) website at http://www.cms.gov/
If you have any questions concerning this matter, please do not hesitate to contact us at SunshineActQuestions@takeda.com.