Transparency and the PPSA

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Dr. Gish: The "Sunshine Act" and Charitable Works

Dr. Gish maintains ethical and long-standing relationships with industry as a specialist physician, translational and clinical research scientist, and expert educator. These collaborations have produced many improvements to patient care and public health over Dr. Gish's 30-year career.

It is a fact that pharmaceutical and molecular diagnositic companies compensate Dr. Gish for his time and renowned expertise. It is also a fact that Dr. Gish contributes significantly to the advancement of liver health across the globe, at his own expense. The latter would not be possible without the former.

Dr. Gish dedicates at least 500 uncompensated hours every year in voluntary leadership roles for professional and advocacy organizations in the U.S., as well as in Vietnam, Philippines, and Armenia. In addition, he charitably supports several nonprofit organizations' liver disease awareness, prevention, detection, and treatment programs.

Transparency & The Age of PPSA


The era of "pharma swag" such as branded pens, note pads, and coffee mugs is long gone. Same with all-expenses paid trips to premier resorts in the name of continuing medical education. These marketing approaches are thankfully a thing of the past.

Dr. Gish applaudes the efforts of the Pharmaceutical Research and Manufacturers of America (PhRMA) and Advanced Medical Technology Association (AvaMed), who strengthened and adopted voluntary Codes of Ethics for interacting with heathcare professionals more than five years ago. In the exorable march towards transparency — these Codes were the first steps towards significant changes in industry/physician relationships that reduced, and in some cases, eliminated, excesses that the public and Congress deemed inappropriate.

The "National Physician Payment Transparency Program" (also known as the Physician Payment Sunshine Act or PPSA for short), requires manufacturers of certain drugs, devices, as well as biological and medical suppliers ("industry") to provide an annual report of any direct or indirect payments to physicians. Administered under the Centers for Medicare and Medicaid, PPSA requires industry to report any payment or transfer of value exceeding $10 made to a "covered entity". This information will then be made available in a public searchable database.

Two federal laws exist - the Anti Kickback Statute (AKS) and the False Claims Act (FCA) - that prohibit or restrict certain types of contractual relationships, investments, and marketing and recruitment practices between physicians and industry. Several states have enacted similar or stronger AKS and FCA laws including California, Colorado, Connecticut, Massachusetts, Minnesota, Nevada, Vermont, Washington DC, and West Virginia. Academic Medical Centers across the U.S. are enforcing very strict conflict-of-interest policies that ban any industry inducements that may influence students, trainees, and faculty clinical practice. Dr. Gish is licensed in both California and Nevada and employed by Acedemic Medical Centers.

Today, a new Affordable Care Act law is being being implemented to further disourage inappropriate influence and conflict of interest between physicians and industry with the goal of controlling the the spiraling cost of prescription medications and medical devices.

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