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

Category - Dispute and Resolution Process

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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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 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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Physician and Teaching Hospital Registration Starts June 1, 2014

CMS has announced that it will open voluntary registration under the Sunshine Act for physicians and teaching hospitals on June 1, 2014. While CMS is encouraging physicians and teaching hospitals to participate, registration is not required. However, only registered physicians and teaching hospitals will be allowed to review...

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There’s An App for That: CMS Mobile Apps for Physicians and Industry

I am writing this week about two mobile apps released by CMS that allow you to track payments and transfers of value on your mobile phone and tablet. The apps are available without cost and can be downloaded from the app store that supports your Android™ or...

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