The Centers for Medicare & Medicaid Services (CMS) recently announced that the Open Payments Program (Sunshine Act) review and dispute process will begin April 6 and end May 21, 2015. During this period, physicians and teaching hospitals have the opportunity to review financial information reported about them by drug and device manufacturers and group purchasing organizations and, if needed, dispute inaccurate data before it is published on June 30, 2015. There will be an additional 15-day period for manufacturers and GPOs to submit final dispute corrections.
Payments covered include consulting fees, honoraria, royalty or license payments, gifts and entertainment, travel, education, etc. Examples of payments covered and definitions can be found on the CMS website.
According to CMS, after the review and dispute period ends, physicians can continue to register and initiate disputes, but resolutions will not be publicly displayed until the next reporting cycle.
To participate in the voluntary review and dispute process in 2015, physicians and teaching hospitals must register in both the CMS Enterprise Identity Management and Open Payments systems. However, those who registered last year do not need to register again. Physicians registering for the first time should set aside about 30 minutes to complete the registration process, which must be done in a single session.
This is the second reporting cycle for the Open Payments program and covers payments made in 2014. Last year, CMS published information on 4.45 million payments valued at $3.7 billion, and those payments were made in just the final five months of 2013.
Source: “Time to Review Your Open Payments Data, “ American Academy of Family Physicians, April 3, 2015.