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Physician Open Payments Program ("Sunshine Act")

What is Open Payments? 

The Open Payments Program, which was a part of the Patient Protection and Affordable Care Act (ACA), is a national transparency program intended to highlight the financial relationships between physicians, teaching hospitals and drug and device manufacturers. Originally known as “The Sunshine Act,” the Centers for Medicare & Medicaid Services (CMS) refers to this program as the physician Open Payments Program. You can find CMS fact sheets, FAQs and additional information at the CMS Open Payments webpage. 

This program requires: 

  1. “applicable manufacturers” of drugs, devices, biological or medical supplies to annually report to CMS certain payments and other transfers of value made to “covered recipients” (physicians or teaching hospitals) 
  2. “applicable manufacturers” and “applicable group purchasing organizations” (GPOs) to annually report to CMS certain ownership interests held by physicians and their immediate family members, and 
  3. “applicable GPOs” to report transfers of value to physician owners. 
As of Aug. 1, 2013, such manufacturers offering products covered by Medicare, Medicaid or the Children’s Health Insurance (CHIP) program are required to report to CMS any payments or other transfers of value to certain physicians and teaching hospitals that are valued at more than $10 or if the aggregate value provided to a physician over the course of a year is more than $100. The first reporting period was Aug. 1 through Dec. 31, 2013. On Sept. 30, 2014 CMS made this information available to the public on a searchable and downloadable website. Beginning in 2014, the data will be collected for the full calendar year, reported to CMS and should be posted by June 30 of the following year. 

Physicians and teaching hospitals have an opportunity to review and dispute erroneous data for each year before it is made publicly available. In order to review the data, CMS requires a two-step process for physician registration. First, physicians must to register in the CMS Enterprise Portal and then to review and, if necessary, dispute the data, they must register separately with the Open Payments program. More information on the registration process can be found on the CMS Open Payments Program Registration page.

CMS Resources: