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

June2015

CMS Delivers Sunshine Act Annual Report to Congress

The Secretary of the Department of Health and Human Services has delivered the agency’s 2014 Annual Report on the Sunshine Act/Open Payments Program to Congress.  The Report, which is required under the Affordable Care Act, describes highlights of the first year of Sunshine Act data gathering and...

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CMS Signals Sunshine Act Compliance Strategy

As the second Sunshine Act/Open Payments reporting period winds down, one question on the mind of many Sunshine Act participants is this:  when will CMS begin enforcement of the Sunshine Act?  The answer, it turns out, is that enforcement efforts are underway. Before I examine those efforts, however,...

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Correction Period for 2014 Data Submissions Ends June 5, 2015

We are nearing the end of the submission cycle for 2014 Sunshine Act/Open Payments data.  The 15-day correction period for 2014 data, and updated 2013 data, will end tomorrow, June 5, 2015.  Applicable manufacturers and applicable group purchasing organizations (GPOs) should use the remaining time to resolve...

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