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

Category - Uncategorized

CMS Releases 2015 Sunshine Act Data

CMS has released Sunshine Act/Open Payments data for the 2015 reporting year.  Now that we have two full years of reported data, we can see whether trends are developing.  Here are some highlights of the 2015 data summary released by CMS: The total number of records reported,...

Read More >

CMS Revises Time for Sunshine Act Special Open Door Forum

CMS has revised the time for the Sunshine Act/Open Payments Special Open Door Forum that CMS will host on August 2, 2016.  The forum will be a conference call now scheduled to take place between 1:30 pm and 3:00 pm EST. The purpose of the Forum is to solicit comments...

Read More >

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...

Read More >

New Registration Link for Upcoming CMS Q&A Session

February 12, 20160 comments
Ruselle W. Robinson

CMS has posted a new registration link for those who wish to ask questions during the Sunshine Act/Open Payments informal question and answer session now scheduled for February 16, 2016.  The Q&A session will take place 2pm to 3pm (EST) In order to ask questions, you must go online and register...

Read More >

CMS Postpones Sunshine Act Q&A Until February 16, 2016

CMS postponed the Sunshine Act/Open Payments informal question and answer session scheduled for today, February 9, 2016, and rescheduled the session for 2 pm (EST) Tuesday, February 16, 2016.  CMS staff will answer questions about the current reporting cycle for 2015 Sunshine Act/Open Payments data. Here is a link to my original...

Read More >

CMS To Host Sunshine Act Q&A on Tuesday, February 9, 2016

CMS will host an informal Question and Answer session on Tuesday, February 9, 2016.  The session will begin at 2pm and conclude at 3pm (EST).  CMS staff members will answer questions about the reporting cycle for 2015 Sunshine Act/Open Payments data, which began February 1, 2016. If you...

Read More >

Dental Device Manufacturers and the Sunshine Act

The Sunshine Act/Open Payments reporting rule for payments and transfers of value by applicable manufacturers appears to be straightforward:  applicable manufacturers of covered products must report payments and other transfers of value they make to physicians if those payments and/or transfers of value meet certain thresholds. Yet, many...

Read More >

Analysis of Sunshine Act Data Reveals Drug Company Marketing Strategies

CMS frequently reminds Sunshine Act critics that the Sunshine Act is a disclosure statute.  CMS reports the data submitted by applicable manufacturers and applicable group purchasing organizations, and the public decides how to use it.  Most commentators who have reported on the 2013 Sunshine Act data have...

Read More >