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

Category - Registration

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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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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Sunshine Act Reporting Period for 2014 Data Ends Today

Today, March 31, 2015, is the last day for applicable manufacturers and applicable group purchasing organizations (GPO) to update 2013 data and submit 2014 data for the upcoming June 30, 2015 publication date. Any applicable manufacturer or applicable GPO that registered and submitted 2013 data must first update...

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Sunshine Act Enforcement on the Horizon?

The 2014 Sunshine Act/Open Payments reporting period comes to an end in a few days on March 31, 2015.  Unlike last year, when complications seemed to arise daily, the second reporting cycle has been relatively calm and lacking in public controversy. On March 10, 2015, CMS held its last live...

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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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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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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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