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How did an interest in healthcare policy lead Robert Platt to a career in the law? Find out more>


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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Six Things to Know Before Buying a Physician Practice spotlight

Dermatology, ophthalmology, radiology, urology…the list goes on. Yet, in any physician practice management transaction, there are six key considerations that apply and, if not carefully managed, can derail a transaction. Download the 6 Things to Know Before Buying a Physician Practice to keep your physician practice management transactions on track.

Click here to download the guide.

FAQs on the New SEC Rules on Pay Ratio

Securities Exchange Law Blog


September 27, 2017

On August 5, 2015, the SEC adopted new rules implementing the pay ratio disclosure requirement of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). Section 953(b) of the Dodd-Frank Act required the SEC to adopt rules requiring reporting companies to disclose the ratio of the annual compensation of the company's median employee to the annual compensation of its principal executive officer. These rules will become effective generally for companies in their Form 10-K for the 2017 fiscal year or in their proxy statement for the 2018 annual meeting. Below are the questions that are answered in the blog post related to the pay ratio rule.

  1. What are the new rules on pay ratio generally?
  2. What companies are required to provide the new pay ratio?
  3. When and where is the new disclosure required?
  4. How do you determine the median employee?
  5. Once the median employee is identified, how do you calculate that employee’s annual total compensation?
  6. How often must the company identify the median employee?
  7. Who is required to be included in the employee population used to determine the median employee?
  8. What are the two exemptions for non-U.S. employees?
  9. What if the company completed an acquisition during the year which included adding new employees?
  10. May the company make any cost-of-living adjustments in the determination of the median employee or in the calculation of the median employee’s annual total compensation?
  11. Must companies use their entire employee population to determine the median employee?
  12. What information other than the pay ratio between the median employee and the PEO must the company disclose and may the company disclose additional information regarding the calculation of the pay ratio?

Securities Law Exchange Blog

To continue reading this article on the firm's Securities Law Exchange blog, please click here to read the FAQs on the New SEC Rules on Pay Ratio. Download the full PDF here

Bass, Berry & Sims' Securities Law Exchange blog features commentary and practical insight on SEC updates for publicly traded companies.

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