“The Sunshine Act” is about to take effect beginning on September 30, 2014. This is a national program being implemented by the Center for Medicare & Medicaid Services (CMS) in order to be more transparent and responsible to the general public. CMS is mandated to publish reported data on September 30, 2014. The first Open Payments program cycle is a partial data collection period of five months (August 1 through December 31, 2013). Each Open Payments program cycle beyond 2013 will consist of a full 12 months of calendar-year data to be collected and reported to CMS.
The program allows physicians and teaching hospitals to register and review the financial data submitted by applicable manufacturers and group purchasing organizations to initiate disputes if necessary before the data is made public.
The deadline is up until 11:59pm (EDT) on September 11, 2014 to review and dispute payments being reported about your organization. In order to dispute the reports, organizations must register with the CMS Enterprise Portal, register in the open payment system to review your payment records and delegate roles and responsibilities by nominating system users to fill specific users roles. Not to worry, CMS estimates that the registration process should only take about thirty minutes and must be completed in a single session.