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

Sunshine Act Reporting Period for 2014 Data Ends Today

March 31, 2015
Ruselle W. Robinson

Today, March 31, 2015, is the last day for applicable manufacturers and applicable group purchasing organizations (GPO) to update 2013 data and submit 2014 data for the upcoming June 30, 2015 publication date.

Any applicable manufacturer or applicable GPO that registered and submitted 2013 data must first update (if necessary) their Sunshine Act/Open Payments profile information, and then recertify that the profile is accurate before submitting 2014 data.  A quick guide to the recertification process can be found here:

http://cms.gov/OpenPayments/Downloads/Applicable-Manufacturer-and-GPO-Registration-and-Re-Certification-%E2%80%93-Quick-Reference-Guide.pdf

Registration for physicians and teaching hospitals is open-ended and ongoing.  The 45-day Review and Dispute Period for registered physicians and teaching hospitals will begin in April and continue into May.  The 15-day Correction Period will follow.  CMS will post the 2014 data and updated 2013 data on its website on June 30, 2015.

I will continue to follow Sunshine Act developments as they occur and provide you with timely updates.

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