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

Category - Phase 2 Registration

CMS Announces Proposed Changes to Sunshine Act Regulations

Just days after the reporting period for 2013 payment and physician ownership data came to a close on June 30, 2014, CMS announced that it is proposing four changes to the Sunshine Act (also known as Open Payments) rule.  The most significant revision to the Sunshine Act...

Read More >

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...

Read More >

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...

Read More >

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...

Read More >

CMS Readies Industry for Phase 2 Data Submission

CMS is preparing Industry (applicable manufacturers and applicable group purchasing organizations) for the opening of Industry’s Phase 2 detailed data submission process. The goal is to have Industry ready to go once Phase 2 commences, and have the data submission process run as smoothly as possible. Phase 2...

Read More >

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...

Read More >

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...

Read More >

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...

Read More >