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

CMS Readies Industry for Phase 2 Data Submission

May 15, 2014
Ruselle W. Robinson

CMS is preparing Industry (applicable manufacturers and applicable group purchasing organizations) for the opening of Industry’s Phase 2 detailed data submission process. The goal is to have Industry ready to go once Phase 2 commences, and have the data submission process run as smoothly as possible.

Phase 2 will start in late May/June 2014 and continue at least 30 days.

Responding to Industry comments, CMS has updated its previously-posted data submission resources. Industry will use these resource to submit their Phase 2 payment and physician ownership data. The changed and updated resources include:

  • Submission Data Mapping Document
  • XML Schema Definition (XSD document)
  • CSV Sample Files and XML Sample Files

A full explanation and listing of the updates and changes can be found here (PDF).

In addition, CMS is developing a series of tutorial videos to explain Phase 2 topics CMS deems to be of vital importance. CMS has posted the first of the video tutorials on its website. This tutorial explains how to use the recently updated data submission resources to format data for upload to the Sunshine Act/Open Payments system. You can view the tutorial by clicking here.

Future tutorials will focus on:

  • How to Register in the Sunshine Act/Open Payments System, explained with step-by-step screenshots
  • How to formally submit data files in the acceptable file formats, and attest to the accuracy of the data

We are entering late May, and I expect CMS to announce the beginning date for Phase 2 shortly. I will update you on the CMS announcement as soon as it happens.


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