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Polsinelli - Health Care Polsinelli - Health Care


July 2014


You Are Now on the Clock — Sunshine Act Dispute Window Now Open







For more information about this e-Alert, please contact:


T. Jeffrey Fitzgerald



Jean Marie R. Pechette



Lauren Z. Groebe



Health Care Practice Leaders:


Matthew J. Murer



Jane E. Arnold



Colleen M. Faddick




To learn more about our Health Care practice, or to contact one of our Health Care attorneys, click here.



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Beginning Monday, July 14, 2014, the review, dispute and correction process outlined the National Physician Payment Transparency Program (also known as the "Sunshine Act") opens on CMS's Open Payments website. Physicians and teaching hospitals can access data about payments they received from drug and device manufacturers for the 2013 reporting period. The window to review and dispute the data is only 45 days (with an additional 15 days to resolve pending disputes).

Under the Sunshine Act (part of the Affordable Care Act), drug and device manufacturers must report to CMS detailed information about payments made to physicians and teaching hospitals. Applicable manufacturers have already reported that data to CMS for the period August 1 through December 31, 2013.

The chance for physicians and teaching hospitals to review and correct this data is limited. Physicians and teaching hospitals have only until August 27, 2014 to preview and dispute information contained within the reports. While optional, this is the only opportunity that physicians and teaching hospitals have to make sure the data reported about them is accurate. CMS won't mediate disputes, so it may take some time to address any errors with the reporting manufacturer. CMS is scheduled to publish the 2013 data on September 30, 2014.

What You Need to Do

Accessing this data requires a two-step registration process: creation of an account in CMS's Enterprise Portal (for identity verification), and registration with the Open Payments System itself. There are instructions for physicians and teaching hospitals.

For More Information

For questions on the contents of this alert, contact an attorney listed within this communication.













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* Law360, March 2014
** The American Lawyer 2013 and 2014 reports







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