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

Category - Compliance

CMS Revises Time for Sunshine Act Special Open Door Forum

CMS has revised the time for the Sunshine Act/Open Payments Special Open Door Forum that CMS will host on August 2, 2016.  The forum will be a conference call now scheduled to take place between 1:30 pm and 3:00 pm EST. The purpose of the Forum is to solicit comments...

Read More >

Sunshine Act Reporting Cycle for 2015 Data is Underway

Consistent with my expectations, CMS announced this morning that today, February 1, 2015, is the first day applicable manufacturers and applicable group purchasing organizations (GPOs) can submit 2015 data on payments or transfers of value, physician ownership, or physician investment interests. Applicable manufacturers and applicable GPOs also can register or recertify their registration in...

Read More >

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,...

Read More >