On February 7, 2014, CMS announced a two-phase registration and data submission process for the 2013 Open Payments Program, the reporting mechanism for the Physician Payment Sunshine Act. Under Phase I, which begins February 18, 2014 and runs through March 31, 2014, applicable manufacturers and applicable group purchasing organizations will register for Open Payments and submit to CMS corporate profile information and aggregate 2013 payment data. Phase 2 begins in May, extends no fewer than 30 days, and includes submission of detailed 2013 payment data and legal attestation to the accuracy of the data. Both phases of data submission will be complete by August 1, at which point the dispute resolution process will begin. According to CMS, this phased approach to Open Payments registration and data submission is for the 2013 program year only.
This article is presented for informational purposes only and is not intended to constitute legal advice.