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

Category - Teaching Hospitals

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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Sunshine Act: New Developments

Following up on its successful publication of 2013 data on the Open Payments website, CMS recently announced several new Sunshine Act/Open Payment developments. Website Search Tool.     Many observers have complained that accessing data on the CMS Open Payments website is cumbersome and time-consuming.  CMS hopes to increase ease of...

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CMS Releases 2015 Teaching Hospital List and Updates Reporting Thresholds

CMS has released the list of teaching hospitals that industry (which includes applicable manufacturers and group purchasing organizations) must use for reporting 2015 payments and other transfers of value.  CMS revises the teaching hospital list every year.  The 2015 list can be found here:  http://www.cms.gov/OpenPayments/Downloads/Teaching-Hospital-List-2014-Open-Payments-Cycle-[October-2014].pdf The Sunshine Act...

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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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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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