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

Correction Period for 2014 Data Submissions Ends June 5, 2015

June 4, 2015
Ruselle W. Robinson

We are nearing the end of the submission cycle for 2014 Sunshine Act/Open Payments data.  The 15-day correction period for 2014 data, and updated 2013 data, will end tomorrow, June 5, 2015.  Applicable manufacturers and applicable group purchasing organizations (GPOs) should use the remaining time to resolve any outstanding disputes initiated by physicians and teaching hospitals during the review and dispute period in April and May 2015.

Applicable manufacturers and applicable GPOs must update and resubmit data that changes as the result of an resolved dispute.  Or, if no change to the data is required, the applicable manufacturers and applicable GPOs must notify CMS that the dispute has been resolved with no change.

CMS will publish data that is the subject of an unresolved dispute as “under dispute” when it releases the 2014 data on June 30, 2015.

Finally, CMS has given notice of its initial Sunshine Act enforcement strategy.  More on that in next week’s post.


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