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

Sunshine Act Reporting Period for 2014 Data is Underway

February 6, 2015
Ruselle W. Robinson

The second Sunshine Act reporting period commenced on February 2, 2015.  Applicable manufacturers and applicable group purchasing organizations (GPOs) must submit their data for any payments or transfers of value that took place during the 2014 calendar year.  In addition, applicable manufacturers and applicable GPOs can submit corrected 2013 data.  As part of the submission process, applicable manufacturers and applicable GPOs must either register in the Sunshine Act/Open Payments system, or recertify their earlier registration.  The reporting period will end on March 31, 2015.

Physician and teaching hospital registration in the Sunshine Act/Open Payments system, which is optional and open-ended, continues.  Only registered physicians and teaching hospitals can review and dispute 2014 data specific to them before CMS publishes the data on its website.  The review and dispute period for 2014 data (and corrected 2013 data) will begin in April 2015.

CMS intends to publish the 2014 data, and the updated 2013 data, in June 2015.

To assist interested parties with the registration and submission process, CMS will hold an informal Question and Answer call-in session between 1:30pm and 2-30pm (EST) on February 10, 2015.  The call-in number is 1-877-267-1577, and the meeting number is 992 284 390.

CMS intends to hold monthly call-in sessions.  If your question isn’t answered during the February session, you can hold it until the next session, or submit it to the Help Desk at openpayments@cms.hhs.gov.

Has CMS ironed out the problems that plagued the initial reporting period covering 2013 data?  Will the sheer volume of 2014 data (12 months of data instead of 5) overwhelm the system?  We will see.  I will continue to provide updates as the reporting period for 2014 data unfolds.

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