The Lowdown on the Sunshine Act: Compliance Essentials for Illinois Doctors

UPDATE: Aug. 28

Upcoming Outages

According to CMS, the Open Payments system will be inaccessible during a series of scheduled maintenance upgrades at the CMS data center in the coming weeks:

Date: Saturday, 8/30/2014
Start Time: 1:00 a.m.
End Time: 11:00 a.m.

Date: Saturday, 9/5/2014
Duration Time: More information to follow next week.

Open Payments Review and Dispute Process Extended to September 10

Access to the Open Payments system will be unavailable for approximately two days due to the upcoming maintenance updates at the CMS Data Center (noted above).

To allow ample time in the review, dispute and correction processes, CMS is extending the deadlines for review and dispute, and correction. The revised timeline is below:

  • Review and dispute (45 days): 7/14/2014 - 8/3/2014, 8/14/2014 - 9/10/2014
  • Correction period (15 days): 9/11/2014 - 9/25/2014

The date for data publication remains the same, September 30, 2014.


The basics

The Physician Payments Sunshine Act (Sunshine Act) requires medical device, biologicals and drug manufacturers to report certain payments and items of value given to physicians.

The underlying reporting system has been under development for several years. We are now in the period when that data isn't yet public, but physicians can review the data reported under their name.

Since this a new reporting system with numerous entities supplying information, it is important that doctors know what is being reported about them before this information becomes accessible by the general public.

The deadline for physicians to access the database and initiate a dispute before their information is made public has been extended until Sept. 10, 2014. The deadline was extended in mid-August due to problems with the site physicians must use to view the data.

General Information for Physicians

AMA Sunshine Act Resources

Getting started

The reporting database is being administered through the Centers for Medicare and Medicaid Services (CMS). In order to review your data you must initiate a two-phase registration and review process through the CMS Enterprise Portal. Once you've completed the first-phase in the portal, you'll be required to complete your registration via the Open Payments system. You'll use the registration credentials acquired in phase 1 to complete this second phase.

It has been reported that the portal registration can be cumbersome, so allow for adequate time to register.

Registration for the CMS Enterprise Portal and Open Payment systems is voluntary; however, registration is required for physicians seeking to review their industry reported data.

Registration Guide - Includes screenshots to follow during the registration process.

Disputes

Once you've reviewed the payment information associated with your name, you have the right to dispute and seek correction of errors.

Understanding the Dispute Process

Instructions for Initiating a Dispute