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

Recent Posts

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 >

CMS Releases Teaching Hospital List and Reporting Thresholds for 2016

CMS has released the list of teaching hospitals that applicable manufacturers must use for reporting 2016 payments and transfers of value.  CMS updates the teaching hospital list every year.  The 2016 list can be found here: https://www.cms.gov/OpenPayments/Downloads/2016-Reporting-Cycle-Teaching-Hospital-List-%5bSeptember-2015%5d.pdf In addition, CMS has published the inflation-adjusted reporting thresholds that applicable...

Read More >

Update on Reporting Sunshine Act 2015 Data

September 17, 20151 comment
Ruselle W. Robinson

Applicable manufacturers and applicable group purchasing organizations (GPOs) are in the homestretch for gathering 2015 Sunshine Act payment and ownership data that they will report in 2016.  A client asked recently about current payment/transfer of value reporting thresholds and the expected reporting timeline in 2016 for 2015...

Read More >

Jury Still Out on Impact of Sunshine Act Disclosures

We have completed two Sunshine Act/Open Payments reporting cycles.  The first cycle, limited to the last five months of 2013, was marred by glitches that affected the reported data’s integrity.  The reporting cycle for 2013 data was, in many ways, a trial run. The second reporting cycle, which...

Read More >

CMS Updates Sunshine Act Guidance on CME Reporting

CMS moved a step closer to implementing the new continuing medical education (CME) reporting requirements with a recent update to the Law and Policy page on the Sunshine Act/Open Payments website.  You can review the updated Law and Policy page here:  http://www.cms.gov/OpenPayments/About/Law-and-Policy.html In October 2014, CMS adopted several...

Read More >

Media Comments on 2014 Sunshine Act Data

As expected, several media outlets have reported on the 2014 Sunshine Act data release. Two journals that report regularly on health care issues, and one online public interest journal, are among the publications that  have interpreted the 2014 Sunshine Act/Open Payments data that CMS published on June 30,...

Read More >

CMS Publishes 2014 Sunshine Act Data

On June 30, 2014, CMS posted 2014 Sunshine Act/Open Payments data on its website.  The 2014 financial data, which covered a full calendar year, included information on 11.41 million financial transactions reported by 1,444 applicable manufacturers and applicable group purchasing organizations.  The reported  payments went to 607,000...

Read More >

CMS Delivers Sunshine Act Annual Report to Congress

The Secretary of the Department of Health and Human Services has delivered the agency’s 2014 Annual Report on the Sunshine Act/Open Payments Program to Congress.  The Report, which is required under the Affordable Care Act, describes highlights of the first year of Sunshine Act data gathering and...

Read More >