overview transparency obligations

Latest update: 14 September 2018 | Important Notes

Report Due Date

May 1


Minnesota Board of Pharmacy — Minnesota Statutes 151.461 and Minnesota Statutes 151.252, subd. 3

Who Must Report

Pharmaceutical manufacturers

Covered Recipients

Advanced practice registered nurses (APRNs)
Physician assistants (PAs)
Dental therapists

Pharmaceutical Companies

What is reported:

Payments, reimbursement or other compensation paid to Minnesota practitioners during the calendar year totaling more than $100 to a particular covered recipient

Data points to be disclosed:

  • Name of practitioner
  • Professional designation
  • Address of practitioner
  • Value of payment
  • Specific reason for payment

How to Report

Reports filed under this provision are public data. Reports must be filed in an electronic format, so please fill out this spreadsheet and return it to the Board either attached to an e-mail (Pharmacy.Board@state.mn.us) or copied onto a CD-ROM.


Gifts to HCPs are prohibited. A “gift” does not include:

  • Items with a total combined retail value, in any calendar year, of not more than $50
  • A payment to the sponsor of a medical conference, professional meeting, or other educational program, provided the payment is not made directly to a practitioner
  • Honoraria and payment of the reasonable expenses
  • Compensation for professional or consulting services for a research project
  • Publications and educational materials
  • Salaries and benefits for employees
Important notes:
  • This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
  • Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information reflects that most recent changes and is still applicable.
  • Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. (In such cases, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of that association).
  • “Due date” means the date on which the transfers of value need to be published. For example, the deadline for submitting/sending the complete information to the authority could be before the due date to give HCPs/HCOs the opportunity to check the data that the pharmaceutical companies/medical device companies are going to disclose.
  • The information does not take into consideration:
    • Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
    • Transparency related to patient organizations (unless the patient organization is considered an HCO)
  • If your company is a member of MedTech/EFPIA (or if the industry association your company belongs to is a member of MedTech/EFPIA), the due dates are as mentioned above for MedTech/EFPIA (end of June), unless a law/regulation specifically states otherwise (e.g., the jurisdiction is suspended/exempted from following MedTech/EFPIA).


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