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

Physicians and Teaching Hospitals: 2014 Update

May 30, 2014
Ruselle W. Robinson

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 recent weeks, CMS has announced:

  • A June 1, 2014 start date for the open-ended physician and teaching hospital registration.
  • A June 1, 2014 start date for Industry’s thirty-day Phase 2 Registration and Data Submission period. “Industry” includes applicable manufacturers and applicable group purchasing organizations (GPOs).
  • A comment period on the dispute and registration process. The comment period will end on Monday, June 2, 2014.

Still to come:

  • June/July 2014. CMS will publish the final dispute and resolution process for 2013 data.
  • July 2014. CMS will commence the dispute and resolution period for registered physicians and teaching hospitals. The present timetable for dispute and resolution is 60 days from start to finish. However, the 60 days could be shortened or extended as a result of comments CMS receives from the public.
  • Late September 2014. CMS will post the 2013 payment and physician ownership data on the Open Payments website.     


  • Comment on the dispute and resolution process by June 2, 2014 if you have concerns. CMS is particularly interested in receiving comments on the negotiation process that will take place when a physician or teaching hospital disputes payment/physician ownership data submitted by an applicable manufacturer or applicable GPO. At present, the process for negotiating has no structure other than a deadline.
  • Register with CMS if you would like an opportunity to preview the payment and physician ownership data that names you before that data is released to the public. Only registered physicians and teaching hospitals will be given an opportunity to challenge the accuracy and/or completeness of the data submitted by applicable manufacturers and applicable GPOs.

I will keep you informed of developments.


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