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

Category - Teaching Hospitals

CMS Announces Sunshine Act/Open Payments Open Door Forum

CMS will host a Special Open Door Forum on August 2, 2016.  The forum will be a conference call that will take place between 1 and 3:30pm EST.  The purpose of the Forum is to solicit comments from stakeholders on issues that relate to future rulemaking by...

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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 Releases Teaching Hospital List and Reporting Thresholds for 2016

CMS has released the list of teaching hospitals that applicable manufacturers must use for reporting 2016 payments and transfers of value.  CMS updates the teaching hospital list every year.  The 2016 list can be found here: https://www.cms.gov/OpenPayments/Downloads/2016-Reporting-Cycle-Teaching-Hospital-List-%5bSeptember-2015%5d.pdf In addition, CMS has published the inflation-adjusted reporting thresholds that applicable...

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Update on Reporting Sunshine Act 2015 Data

September 17, 20151 comment
Ruselle W. Robinson

Applicable manufacturers and applicable group purchasing organizations (GPOs) are in the homestretch for gathering 2015 Sunshine Act payment and ownership data that they will report in 2016.  A client asked recently about current payment/transfer of value reporting thresholds and the expected reporting timeline in 2016 for 2015...

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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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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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