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

Recent Posts

CMS Juggles Dates Once Again

September 9, 20140 comments
Ruselle W. Robinson

CMS has extended the review and dispute period an additional day, to midnight on September 11, 2014.  CMS cited inaccessibility of the Open Payment system during recent maintenance upgrades as the reason for the extension. The 15-day correction period for applicable manufacturers and applicable group purchasing organizations will...

Read More >

CMS Announces Maintenance Shutdown for Open Payments System; Review, Dispute and Correction Process Extended Two Days

CMS today announced that it will shut down the Open Payments system for scheduled maintenance upgrades on Saturday, August 30, 2014, and again on September 5, 2014. The system will be inaccessible on August 30th for a period beginning at 1:00 am and ending at 11:00 am. CMS will...

Read More >

Physician and Teaching Hospital Registration Re-Opens for Review and Dispute

CMS announced today that the Sunshine Act/Open Payments system is back online.  Registered physicians and teaching hospitals once again can review (and dispute, if necessary) payment and physician ownership data reported about them by applicable manufacturers and applicable group purchasing organizations. CMS shut down the Open Payments system earlier...

Read More >

Registration for Review, Dispute and Correction Hits Snag

Earlier this week, the online publication ProPublica reported that CMS had temporarily suspended the review and dispute phase of Open Payments, which began on July 14, 2014.  According to the article, in at least one instance a manufacturer submitted incorrect payment information after confusing two physicians with the same...

Read More >

What’s New: Sunshine Act Regulatory Changes

In my post of July 7, 2014, I wrote about proposed amendments to the Sunshine Act regulations that subsequently appeared in the July 11, 2014 Federal Register. Today I am giving more detail about the four proposed modifications to the Sunshine Act regulations.  I will pay particular attention...

Read More >

Review, Dispute and Correction Process Begins July 14, 2014

The day finally has arrived. The Sunshine Act review, dispute and correction process (formerly known as the dispute resolution process) began on July 14, 2014 and will run through September 11, 2014, a total of 60 days. The review, dispute and correction process will be divided into two periods. ...

Read More >

CMS Announces Proposed Changes to Sunshine Act Regulations

Just days after the reporting period for 2013 payment and physician ownership data came to a close on June 30, 2014, CMS announced that it is proposing four changes to the Sunshine Act (also known as Open Payments) rule.  The most significant revision to the Sunshine Act...

Read More >

Dispute Resolution, Continued

CMS continues to work towards its September 30, 2014 publication date for 2013 payment and physician ownership data.  Phase 2 registration for Industry (applicable manufacturers and applicable group purchasing organizations (GPOs)) will close on June 30th.  Physicians and teaching hospitals are still registering with CMS so that they can...

Read More >