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

Category - Physicians

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...

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Sunshine Act Developments

CMS recently announced that it has updated Sunshine Act/Open Payments data to include financial data submitted by applicable manufacturers and applicable group purchasing organizations (GPOs) since June 30, 2015.  The updated data includes payments and transfers of value to physicians and teaching hospitals, as well as physician...

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Jury Still Out on Impact of Sunshine Act Disclosures

We have completed two Sunshine Act/Open Payments reporting cycles.  The first cycle, limited to the last five months of 2013, was marred by glitches that affected the reported data’s integrity.  The reporting cycle for 2013 data was, in many ways, a trial run. The second reporting cycle, which...

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CMS Updates Sunshine Act Guidance on CME Reporting

CMS moved a step closer to implementing the new continuing medical education (CME) reporting requirements with a recent update to the Law and Policy page on the Sunshine Act/Open Payments website.  You can review the updated Law and Policy page here:  http://www.cms.gov/OpenPayments/About/Law-and-Policy.html In October 2014, CMS adopted several...

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Media Comments on 2014 Sunshine Act Data

As expected, several media outlets have reported on the 2014 Sunshine Act data release. Two journals that report regularly on health care issues, and one online public interest journal, are among the publications that  have interpreted the 2014 Sunshine Act/Open Payments data that CMS published on June 30,...

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CMS Publishes 2014 Sunshine Act Data

On June 30, 2014, CMS posted 2014 Sunshine Act/Open Payments data on its website.  The 2014 financial data, which covered a full calendar year, included information on 11.41 million financial transactions reported by 1,444 applicable manufacturers and applicable group purchasing organizations.  The reported  payments went to 607,000...

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CMS Delivers Sunshine Act Annual Report to Congress

The Secretary of the Department of Health and Human Services has delivered the agency’s 2014 Annual Report on the Sunshine Act/Open Payments Program to Congress.  The Report, which is required under the Affordable Care Act, describes highlights of the first year of Sunshine Act data gathering and...

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CMS Signals Sunshine Act Compliance Strategy

As the second Sunshine Act/Open Payments reporting period winds down, one question on the mind of many Sunshine Act participants is this:  when will CMS begin enforcement of the Sunshine Act?  The answer, it turns out, is that enforcement efforts are underway. Before I examine those efforts, however,...

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