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

Category - Applicable Group Purchasing Organizations (GPOs)

Review, Dispute and Correction Process Begins July 14, 2014

The day finally has arrived. The Sunshine Act review, dispute and correction process (formerly known as the dispute resolution process) began on July 14, 2014 and will run through September 11, 2014, a total of 60 days. The review, dispute and correction process will be divided into two periods. ...

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CMS Announces Proposed Changes to Sunshine Act Regulations

Just days after the reporting period for 2013 payment and physician ownership data came to a close on June 30, 2014, CMS announced that it is proposing four changes to the Sunshine Act (also known as Open Payments) rule.  The most significant revision to the Sunshine Act...

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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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Physicians and Teaching Hospitals: 2014 Update

Today I am giving a 2014 status report for physicians and teaching hospitals. The pace is picking up for Sunshine Act implementation. CMS clearly intends to meet its goal of posting 2013 payment and physician ownership data on the Sunshine Act/Open Payments website by the end of September 2014.  In...

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Industry Phase 2 Registration and Data Submission Starts June 1, 2014

CMS has announced that Industry’s Phase 2 registration and data submission will start June 1, 2014 and run through June 30, 2014. The term “Industry” includes applicable manufacturers and applicable group purchasing organizations (GPOs). Phase 2 will be a two-step process. Step 1 runs June 1--June 30, 2014 , and Step...

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CMS Readies Industry for Phase 2 Data Submission

CMS is preparing Industry (applicable manufacturers and applicable group purchasing organizations) for the opening of Industry’s Phase 2 detailed data submission process. The goal is to have Industry ready to go once Phase 2 commences, and have the data submission process run as smoothly as possible. Phase 2...

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CMS Invites Comment on Sunshine Act Dispute and Resolution Process

On May 5, 2014, CMS published a Comment Request in the Federal Register seeking public input on the Sunshine Act/Open Payments dispute and resolution process. CMS is particularly interested in comments on the interaction between physicians/teaching hospitals and applicable manufacturers/applicable group purchasing organizations (GPOs) during dispute and resolution negotiations.       I discussed...

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