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

Sunshine Act Reporting Cycle for 2015 Data is Underway

February 1, 2016
Ruselle W. Robinson

Consistent with my expectations, CMS announced this morning that today, February 1, 2015, is the first day applicable manufacturers and applicable group purchasing organizations (GPOs) can submit 2015 data on payments or transfers of value, physician ownership, or physician investment interests.

Applicable manufacturers and applicable GPOs also can register or recertify their registration in the Sunshine Act/Open Payments system.

The submission period for 2015 data will run through March 31, 2016.  The 45-day review and dispute period for physicians and teaching hospitals will follow beginning in April and ending mid-to-late May.  The 15-day correction period for applicable manufacturers and applicable GPOs will end in late May/June.  CMS intends to publish the 2015 data on its website on June 30, 2015.

Reminder:  physicians and teaching hospitals must register in the Sunshine Act/Open Payments system before they can review and dispute their reported data.

This year is the third reporting cycle of Sunshine Act/Open Payments data.  The second year certainly ran more smoothly than the first year’s potholed effort to collect partial 2013 data.  Ideally for CMS, this year’s submission period will be uneventful.

One open question–will this be the year CMS starts to assess penalties for non-compliance?

As always, I will keep you up to date as events unfold.

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