A blog by attorneys for anyone interested in or affected by The Sunshine Act.


Dispute Resolution, Continued

CMS continues to work towards its September 30, 2014 publication date for 2013 payment and physician ownership data.  Phase 2 registration for Industry (applicable manufacturers and applicable group purchasing organizations (GPOs)) will close on June 30th.  Physicians and teaching hospitals are still registering with CMS so that they can...

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Dispute and Resolution Update

CMS clearly is rethinking the dispute and resolution process as a result of submissions it received during the comment period that ended on June 2, 2014. Consider, for example, the revised Open Payments User Guide released by CMS on June 6, 2014. Chapter 8 of the Guide,...

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