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

Phase 1 Registration Ends March 31st

March 26, 2014
Ruselle W. Robinson

CMS has issued a reminder that Phase 1 registration for applicable manufacturers will come to a close on March 31, 2014.  Registration is required for all applicable manufacturers with 2013 payment or other transfer of value data to report.

As I described in my last post, Phase 1 registration is a two-step process.  The first step is registration in the CMS Enterprise Portal.  The second step is submission of corporate profile information and aggregate 2013 payment data.

The CMS reminder urges applicable manufacturers to start as early as possible with the registration process because completing both steps of Phase 1 can be time-consuming.  Applicable manufacturers that wait until the last minute risk being non-compliant with Phase 1 requirements.

CMS has posted detailed instructions for completing both Phase 1 steps on its Open Payments Program Registration webpage.

Phase 2 (applicable manufacturer submission of detailed payment and transfer of value data)  is still scheduled to begin in May 2014.  CMS will issue Phase 2 information and instructions later this spring.  I will post the Phase 2 information when it becomes available.

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