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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

303.583.8205

jfitzgerald@polsinelli.com

  

Jean Marie R. Pechette

312.873.3690

jpechette@polsinelli.com

  

Lauren Z. Groebe

816.572.4588

lgroebe@polsinelli.com

  

Health Care Practice Leaders:

  

Matthew J. Murer

312.873.3603

mmurer@polsinelli.com

  

Jane E. Arnold

312.622.6687

jarnold@polsinelli.com

  

Colleen M. Faddick

303.583.8201

jarnold@polsinelli.com

  

  

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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Polsinelli is a first generation Am Law 100 firm serving corporations, institutions, entrepreneurs and individuals nationally. Our attorneys successfully build enduring client relationships by providing practical legal counsel infused with business insight, and with a passion for assisting General Counsel and CEOs in achieving their objectives. Polsinelli is ranked 18th in number of U.S. partners* and has more than 740 attorneys in 19 offices. Profiled by The American Lawyer and ranked as the fastest growing U.S. law firm over a six-year period**, the firm focuses on healthcare, financial services, real estate, life sciences and technology, energy and business litigation, and has depth of experience in 100 service areas and 70 industries. The firm can be found online at www.polsinelli.com. Polsinelli PC. In California, Polsinelli LLP.

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

  

 
 

  

     

  

 
 

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