Extract to table

Any transfers of value to such individuals must be tracked and reported

For CY2024 data (the first reporting year relevant to SBI), the thresholds are as follows: • Per-instance threshold: A transfer of value must be reported if it equals or exceeds $12

49 per-instance threshold, the transfer must be reported if the aggregate of all transfers to a single covered recipient during the calendar year equals or exceeds $100

CY2024 data (October 1, 2024 through December 31, 2024, representing SBI's first three months of commercial activity) must be reported to CMS by March 31, 2025

CY2025 data (January 1 through December 31, 2025) must be reported to CMS by March 31, 2026

" CMS distinguishes between consulting fees (for advisory and consulting services) and honoraria (for speaking and presentation services), and SBI must ensure that each payment is classified in the correct category