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

Category - Registration

Registration for Review, Dispute and Correction Hits Snag

Earlier this week, the online publication ProPublica reported that CMS had temporarily suspended the review and dispute phase of Open Payments, which began on July 14, 2014.  According to the article, in at least one instance a manufacturer submitted incorrect payment information after confusing two physicians with the same...

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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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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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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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