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

Category - Dispute and Resolution Process

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 >

Update on Reporting Sunshine Act 2015 Data

September 17, 20151 comment
Ruselle W. Robinson

Applicable manufacturers and applicable group purchasing organizations (GPOs) are in the homestretch for gathering 2015 Sunshine Act payment and ownership data that they will report in 2016.  A client asked recently about current payment/transfer of value reporting thresholds and the expected reporting timeline in 2016 for 2015...

Read More >

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...

Read More >

Sunshine Act Correction Period Starts Today and Ends June 5, 2015

CMS announced today that the Correction Period for 2014 data submissions starts May 21, 2015 and will end on June 5, 2015 (not June 3, 2015 as a I stated in my last post). Applicable manufacturers and applicable group purchasing organizations (GPOs) must work directly with physicians and...

Read More >

Sunshine Act Dispute and Resolution Period Ends Today, May 20, 2015

Today is the last day for physicians and teaching hospitals to review and dispute their 2014 Sunshine Act/Open Payments data submitted by applicable manufacturers and applicable group purchasing organizations (GPO). The dispute and resolution process encountered problems in early April, including a loss of several days worth of...

Read More >

CMS Extends 2014 Data Submission Period to Friday, April 3, 2015

CMS announced yesterday that it would extend the 2014 data submission period for an additional three days to accommodate late filing applicable manufacturers and applicable group purchasing organizations (GPOs).  The 2014 data submission period will now end at midnight (Eastern Standard Time) on Friday, April 3, 2015. The...

Read More >

Sunshine Act Reporting Period for 2014 Data Ends Today

Today, March 31, 2015, is the last day for applicable manufacturers and applicable group purchasing organizations (GPO) to update 2013 data and submit 2014 data for the upcoming June 30, 2015 publication date. Any applicable manufacturer or applicable GPO that registered and submitted 2013 data must first update...

Read More >

Sunshine Act Enforcement on the Horizon?

The 2014 Sunshine Act/Open Payments reporting period comes to an end in a few days on March 31, 2015.  Unlike last year, when complications seemed to arise daily, the second reporting cycle has been relatively calm and lacking in public controversy. On March 10, 2015, CMS held its last live...

Read More >