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

Sunshine Act Correction Period Starts Today and Ends June 5, 2015

May 21, 2015
Ruselle W. Robinson

CMS announced today that the Correction Period for 2014 data submissions starts May 21, 2015 and will end on June 5, 2015 (not June 3, 2015 as a I stated in my last post).

Applicable manufacturers and applicable group purchasing organizations (GPOs) must work directly with physicians and teaching hospitals to resolve disputed data.  CMS will not mediate any disputes.

For applicable manufacturers and applicable GPOs, here is a link to a CMS reference guide for dispute resolution that results in no change to the data:

https://www.cms.gov/OpenPayments/Downloads/Quick-Reference-Guide-Acknowledging-Disputes-and-Resolving-With-No-Change-%5bApril-2015%5d.pdf

And here is a link to another CMS reference guide, this one for dispute resolution resulting in correction of data:

https://www.cms.gov/OpenPayments/Downloads/Quick-Reference-Guide-Correcting-and-Resolving-Disputes-%5bApril-2015%5d.pdf

The publication date for 2014 data and updated 2013 data remains June 30, 2015.

You can submit questions to the Help Desk by email addressed to openpayments@cms.hhs.gov, or by calling 1-855-326-8366. The phone lines are open Monday–Friday, from 7:30 a.m. to 6:30 p.m. (CT). CMS states that the peak call time is between 11:00 a.m. and 2:00 p.m. (CT), so call earlier or later for better service.

I will keep you up to date on Sunshine Act/Open Payments developments. Stay tuned.

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