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

CMS Invites Comment on Sunshine Act Dispute and Resolution Process

May 8, 2014
Ruselle W. Robinson

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 dispute and resolution in my post of April 3, 2014. CMS intends to begin the 60-day dispute and resolution process after applicable manufacturers and applicable GPOs have submitted all of their 2013 payment and physician ownership data. CMS has not set a start date for dispute and resolution of 2013 data, but still expects to publish 2013 payment and physician ownership data at the end of September 2014.  You can view the CMS webpage on dispute and resolution here:  http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Dispute-and-Resolution.html

Do you have thoughts on improving the dispute and resolution process?  The comment period ends on June 2, 2014. You can read the CMS Comment Request, which includes instructions for submitting comments, here: https://www.federalregister.gov/articles/2014/05/05/2014-10228/agency-information-collection-activities-submission-for-omb-review-comment-request#.



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