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

Category - Phase 1 Registration

Dispute and Resolution for Physicians and Teaching Hospitals

I am focusing today on the Sunshine Act dispute and resolution process through which “physicians” and teaching hospitals can dispute inaccurate payment data. I used quotation marks around the term “physicians” because “physicians” includes medical and osteopathic doctors, dentists, dental surgeons, chiropractors, optometrists and podiatrists. CMS defines...

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Welcome to the Sunshine Act Blog

Welcome to the Sunshine Act Blog. My name is Russ Robinson. I am an attorney in the Health Care Department at Posternak Blankstein & Lund, LLP, a Boston law firm. I will be making regular posts updating you on recent developments on the Sunshine Act, also known...

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Phase 1 Registration Ends March 31st

CMS has issued a reminder that Phase 1 registration for applicable manufacturers will come to a close on March 31, 2014.  Registration is required for all applicable manufacturers with 2013 payment or other transfer of value data to report. As I described in my last post, Phase 1...

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CMS Announces Two-Phase Registration Process

CMS recently announced a two-phase process for registering “applicable manufacturers” who must report 2013 payment data to CMS. The CMS announcement can be found at www.cms.gov/regulations-and-guidance/legislation/national-physician-payment-transparency-program/program-registration.htr. The announcement includes step-by-step instructions for the Phase 1 registration process I describe below. The definition of an “applicable manufacturer” is an...

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