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

Update on Reporting Sunshine Act 2015 Data

September 17, 2015
Ruselle W. Robinson

Applicable manufacturers and applicable group purchasing organizations (GPOs) are in the homestretch for gathering 2015 Sunshine Act payment and ownership data that they will report in 2016.  A client asked recently about current payment/transfer of value reporting thresholds and the expected reporting timeline in 2016 for 2015 data.  Here are the answers to his questions, with the 2015 list of teaching hospitals thrown in as a bonus.

Reporting Thresholds

A manufacturer is not required to submit 2015 data on a payment/transfer of value to a covered recipient that is less than $10.21, unless the total payments/transfers of value to that covered recipient exceed $102.07 during the year.  CMS will use an inflation adjustment to increase these reporting thresholds for 2016 data.

Reporting Timeline

CMS intends to standardize its Sunshine Act reporting calendar as much as possible.  Last year, the announced reporting period for manufacturers and GPOs to submit 2014 data was February 1 through March 31, 2015 (the March 31 deadline slipped to April 3, 2015).  I anticipate that CMS will announce the reporting period for manufacturers and GPOs to submit 2015 data will be February 1, 2016 through March 31, 2016.

The remainder of the timeline for 2015 data will depend on whether CMS keeps to the March 31, 2016 reporting deadline, as well as other hard-to-anticipate factors (technological glitches, for example).  The reporting period will be followed by a 45-day review and resolution period, which will end in mid-to-late May 2016.

The 45-day review and resolution period will be followed by a 15-day correction period that will end in early June 2016.

I expect CMS to publish the 2015 data on June 30, 2016.

Teaching Hospitals

Here is the 2015 list of teaching hospitals:


I will post additional information on reporting of 2015 data as it becomes available.  Stay tuned.


Bill Young says:

I am writing on behalf of WorldDataOnline (https://worlddata.online), an organization which is dedicated to categorizing and adding value to complex open healthcare data, making it accessible for all.

As you are probably aware, on Thursday of last week, the latest Sunshine Act, Open Payments data was released by Centers for Medicare & Medicaid Services. Our data scientists spent the weekend analyzing the new data and have found major, unexplainable, discrepancies affecting approximately 330,000 physicians (circa. 40% of the doctors). A top line summary of our findings are available for you at:


At present we are waiting CMS’s comments, which are slow in forthcoming, and we have held back distributing our findings to a wider audience. We do consider this a major issue which requires CMS’s urgent attention. We are willing to do a further, deeper research with a media partner who equally believes the story to be of interest to their audience.

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