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

Category - Dispute and Resolution Process

Sunshine Act Reporting Period for 2014 Data is Underway

The second Sunshine Act reporting period commenced on February 2, 2015.  Applicable manufacturers and applicable group purchasing organizations (GPOs) must submit their data for any payments or transfers of value that took place during the 2014 calendar year.  In addition, applicable manufacturers and applicable GPOs can submit...

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CMS Outlines 2015 Sunshine Act Reporting Schedule

Douglas Brown, a Deputy Director of CMS, spoke this week at the Pharmaceutical Compliance Congress and Best Practice Forum  in Washington D.C.  As part of his presentation on the Sunshine Act,  Mr. Brown disclosed the 2015 schedule CMS will use for reporting of 2014 payment and physician...

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Sunshine Act: New Developments

Following up on its successful publication of 2013 data on the Open Payments website, CMS recently announced several new Sunshine Act/Open Payment developments. Website Search Tool.     Many observers have complained that accessing data on the CMS Open Payments website is cumbersome and time-consuming.  CMS hopes to increase ease of...

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Learning Curve: CMS Posts 2013 Data

CMS held to its schedule and released the 2013 Sunshine Act data on September 30, 2014.  CMS also published a summary of the Sunshine Act/Open Payments data that held a few surprises.  Here’s what we know so far (all of the numbers are rounded): The total value of...

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CMS Juggles Dates Once Again

September 9, 20140 comments
Ruselle W. Robinson

CMS has extended the review and dispute period an additional day, to midnight on September 11, 2014.  CMS cited inaccessibility of the Open Payment system during recent maintenance upgrades as the reason for the extension. The 15-day correction period for applicable manufacturers and applicable group purchasing organizations will...

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CMS Announces Maintenance Shutdown for Open Payments System; Review, Dispute and Correction Process Extended Two Days

CMS today announced that it will shut down the Open Payments system for scheduled maintenance upgrades on Saturday, August 30, 2014, and again on September 5, 2014. The system will be inaccessible on August 30th for a period beginning at 1:00 am and ending at 11:00 am. CMS will...

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Physician and Teaching Hospital Registration Re-Opens for Review and Dispute

CMS announced today that the Sunshine Act/Open Payments system is back online.  Registered physicians and teaching hospitals once again can review (and dispute, if necessary) payment and physician ownership data reported about them by applicable manufacturers and applicable group purchasing organizations. CMS shut down the Open Payments system earlier...

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Registration for Review, Dispute and Correction Hits Snag

Earlier this week, the online publication ProPublica reported that CMS had temporarily suspended the review and dispute phase of Open Payments, which began on July 14, 2014.  According to the article, in at least one instance a manufacturer submitted incorrect payment information after confusing two physicians with the same...

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