Issue Background

Sunshine Act

The “Physician Payments Sunshine Act” requires that data on payments and gifts made to physicians and teaching hospitals by medical device and pharmaceutical companies be publicly available on a searchable federal database, starting in September 2014. The Centers for Medicare & Medicaid Services (CMS) releases these data, which have been collected since 2013, under what it is calling the “Open Payments Program.”

Important Update: Beginning June 1, 2014, physicians and teaching hospital representatives can register on the CMS Enterprise Portal. Registration is a voluntary process, but only registered users will be able to dispute information reported by industry that they believe to be inaccurate or incomplete.

Registration will be conducted in two phases for the first Open Payments reporting year:

  • Phase 1 (begins June 1) includes user registration in CMS' Enterprise Portal.
  • Phase 2 (begins in July) includes physician and teaching hospital registration in the Open Payments system.

Registered physicians and teaching hospital representatives will be allowed to review and dispute data submitted by applicable manufacturers and applicable group purchasing organizations prior to public posting of the data.


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