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

Recent Posts

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...

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CMS Updates Sunshine Act/Open Payments User Guide

December 22, 20140 comments
Ruselle W. Robinson

Just in time for the next Sunshine Act reporting cycle, CMS has updated the Open Payments User Guide.  The User Guide is a comprehensive Sunshine Act resource for applicable manufacturers, applicable group purchasing organizations (GPOs), physicians and teaching hospitals.  The updated User Guide, Version 3.2 dated December...

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What’s New Under the Sunshine Act

December 15, 20140 comments
Ruselle W. Robinson

CMS wants everyone to understand the recent changes to the continuing education reporting requirement, as well as the three other recent revisions to the Sunshine Act regulation.  I discussed these rule changes in my November 28, 2014 blog post.  Here is link to that post:  http://www.sunshineactpbl.com/cms-issues-final-amendments-sunshine-act-regulation/ Accordingly, CMS has posted...

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CMS Issues Final Amendments to Sunshine Act Regulation

November 28, 20141 comment
Ruselle W. Robinson

CMS recently published in the Federal Register final amendments to the Sunshine Act regulation.  The proposed amendments first appeared in the July 11, 2014 Federal Register.  I wrote about the proposed amendments in my post of July 29, 2014, which you can find here: http://www.sunshineactpbl.com/whats-new-sunshine-act-regulatory/ The proposed amendments...

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CMS Outlines 2015 Sunshine Act Reporting Schedule

Douglas Brown, a Deputy Director of CMS, spoke this week at the Pharmaceutical Compliance Congress and Best Practice Forum  in Washington D.C.  As part of his presentation on the Sunshine Act,  Mr. Brown disclosed the 2015 schedule CMS will use for reporting of 2014 payment and physician...

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Sunshine Act: New Developments

Following up on its successful publication of 2013 data on the Open Payments website, CMS recently announced several new Sunshine Act/Open Payment developments. Website Search Tool.     Many observers have complained that accessing data on the CMS Open Payments website is cumbersome and time-consuming.  CMS hopes to increase ease of...

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CMS Releases 2015 Teaching Hospital List and Updates Reporting Thresholds

CMS has released the list of teaching hospitals that industry (which includes applicable manufacturers and group purchasing organizations) must use for reporting 2015 payments and other transfers of value.  CMS revises the teaching hospital list every year.  The 2015 list can be found here:  http://www.cms.gov/OpenPayments/Downloads/Teaching-Hospital-List-2014-Open-Payments-Cycle-[October-2014].pdf The Sunshine Act...

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Learning Curve: CMS Posts 2013 Data

CMS held to its schedule and released the 2013 Sunshine Act data on September 30, 2014.  CMS also published a summary of the Sunshine Act/Open Payments data that held a few surprises.  Here’s what we know so far (all of the numbers are rounded): The total value of...

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