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

Recent Posts

Dispute and Resolution Update

CMS clearly is rethinking the dispute and resolution process as a result of submissions it received during the comment period that ended on June 2, 2014. Consider, for example, the revised Open Payments User Guide released by CMS on June 6, 2014. Chapter 8 of the Guide,...

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Physicians and Teaching Hospitals: 2014 Update

Today I am giving a 2014 status report for physicians and teaching hospitals. The pace is picking up for Sunshine Act implementation. CMS clearly intends to meet its goal of posting 2013 payment and physician ownership data on the Sunshine Act/Open Payments website by the end of September 2014.  In...

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Industry Phase 2 Registration and Data Submission Starts June 1, 2014

CMS has announced that Industry’s Phase 2 registration and data submission will start June 1, 2014 and run through June 30, 2014. The term “Industry” includes applicable manufacturers and applicable group purchasing organizations (GPOs). Phase 2 will be a two-step process. Step 1 runs June 1--June 30, 2014 , and Step...

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CMS Readies Industry for Phase 2 Data Submission

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...

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CMS Invites Comment on Sunshine Act Dispute and Resolution Process

On May 5, 2014, CMS published a Comment Request in the Federal Register seeking public input on the Sunshine Act/Open Payments dispute and resolution process. CMS is particularly interested in comments on the interaction between physicians/teaching hospitals and applicable manufacturers/applicable group purchasing organizations (GPOs) during dispute and resolution negotiations.       I discussed...

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Physician and Teaching Hospital Registration Starts June 1, 2014

CMS has announced that it will open voluntary registration under the Sunshine Act for physicians and teaching hospitals on June 1, 2014. While CMS is encouraging physicians and teaching hospitals to participate, registration is not required. However, only registered physicians and teaching hospitals will be allowed to review...

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There’s An App for That: CMS Mobile Apps for Physicians and Industry

I am writing this week about two mobile apps released by CMS that allow you to track payments and transfers of value on your mobile phone and tablet. The apps are available without cost and can be downloaded from the app store that supports your Android™ or...

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Definitions of Common Sunshine Act Terms

I thought it would be helpful to provide definitions of common Sunshine Act terms in a single list that you can refer to when reading future posts. I suggest that all physicians review, in particular, the definition of Nature of Payment Categories (No. 13) so that you...

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