Sunshine Act Physician Registration Open

Effective June 1, physicians can complete the first phase of registration that will be necessary to review and appeal information about their relationships with industry before it is made available to the public later this year. 

Passed as part of the Affordable Care Act, the "Physicians Payments Sunshine Act," now known as "Open Payments," requires that certain manufacturers and group purchasing organizations (GPOs) report to the Centers for Medicare and Medicaid Services (CMS) information about payments or other transfers of value they've made to physicians or teaching hospitals. Manufacturers have begun submitting data to CMS on payments or values of transfers made to physicians and teaching hospitals between August 1 and December 31, 2013. The law requires that these providers be given at least 45 days to review and challenge any inaccurate or misleading data before it is made public. 

Physicians wanting to review their data must register with CMS. This registration process will occur in two phases. As the first step, physicians must register in CMS' Enterprise Portal. To complete the process, physicians will need to register in the Open Payments System, which will open in July. Phase 2 of registration will coincide with 45-day review and dispute period. While it was always envisioned that physicians would have ample time to register within the system before the 45-day review period, implementation delays have forced a condensed timeline. Therefore, it is even more critical that physicians complete Phase 1 of the registration process now if they want sufficient time to review information that, by law, must be made public no later than September 30 of this year.

CMS will create a process by which a physician will be able to contact a manufacturer or GPO that has submitted misleading or false information in an attempt to resolve the disputed submission. If the dispute cannot be resolved, CMS will allow an additional 15 days to achieve resolution before the information is made public. If resolution is still not reached, the information will be flagged as in dispute on the public Webpage.

CMS will host a provider call on the registration process on June 12, 1:30-3 pm. More information about Open Payments is available on CMS' Website.