Connecticut Delays Sunshine Reporting For APRNs Until 2017
Connecticut recently passed a law requiring manufacturers to report their transfers of value made to advance practice registered nurses (APRNs) practicing in Connecticut. This group includes nurse practitioners, clinical nurse specialists, nurse anesthetists, and nurse midwives. APRNs are excluded from the reporting obligations under the Federal Physician Payments Sunshine Act, but Connecticut passed this disclosure requirement as part of a new initiative allowing APRNs to practice and prescribe independently of physicians. This law was originally supposed to go into effect July 1, 2015.
On Friday, April 24, Connecticut enacted Public Act 15-4, which pushed the start date back to July 1, 2017. The new law also shifts the reporting requirements from a quarterly obligation to an annual obligation.
(b) (1) Not later than July 1,  2017, and [quarterly] annually thereafter, an applicable manufacturer that provides a payment or other transfer of value to an advanced practice registered nurse, who is practicing not in collaboration with a physician in the state, in accordance with subsection (b) of section 20-87a, as amended by this act, shall submit to the Commissioner of Consumer Protection, in the form and manner prescribed by the commissioner, the information described in 42 USC 1320a-7h, as amended from time to time, for the preceding calendar year.
(2) In determining whether an applicable manufacturer is required to submit information concerning a payment or other transfer of value to an advanced practice registered nurse in accordance with the provisions of this subsection, the applicable manufacturer shall refer to the list of advanced practice registered nurses who are authorized to practice not in collaboration with a physician published by the Commissioner of Public Health on the Department of Public Health's Internet web site in accordance with subsection (b) of section 20-87a, as amended by this act.
Another complicated aspect of Connecticut reporting is that manufacturers must keep track of which APRNs have made the decision to work independently and have the ability to prescribe, and only track and report those payments. Public Act 15-4 also provides some insight into how manufacturers should best keep tabs on APRNs practicing in the state.
Not later than December first, annually, the Commissioner of Public Health shall publish on the department's Internet web site a list of such advanced practice registered nurses who are authorized to practice not in collaboration with a physician.