Physician Payment Sunshine Act

The Physician Payments Sunshine Act (Sunshine Act), which is part of the Affordable Care Act (ACA), requires manufacturers of drugs, medical devices, and biologicals that participate in U.S. federal health care programs to report certain payments and items of value given to physicians and teaching hospitals. Manufacturers submit the reports to the Centers for Medicare & Medicaid Services (CMS) on an annual basis. In addition, manufacturers and group purchasing organizations (GPOs) must report certain ownership interests held by physicians and their immediate family members.

The majority of the information contained in the reports are available on a public, searchable website. Physicians have the right to review their reports and to challenge data that are false, inaccurate, or misleading.

Significant Dates

April 6, 2015: CMS begins to publish payment data from calendar year 2014.

May 20, 2015: Final day for physicians to initiate disputes of erroneous data from calendar year 2013 2014 reported for transfers made and ownerships held. If a physician waits until after data have been made public to initiate a dispute, the data will not be flagged as disputed in the public database until CMS updates the information.

June 30, 2015: 2014 data are published in the public database.

December 31, 2015: All disputes of erroneous data from calendar year 2014 must be submitted to receive consideration by CMS.

Early 2016: Data will be refreshed and updated for the full calendar year of 2014 financial data.

Three-Step Verification and Registration Process To Review Data

Step 1: Complete CMS e-verification process
CMS requires a two-phase registration process. In phase one, physicians are required to complete CMS' e-verification process via the CMS Enterprise Portal (EIDM).

Step 2: Register with CMS' Open Payments
Following the completion of Step 1 and gaining access via the EIDM, physicians can move onto phase two and register in CMS' Open Payments System. (Reference guide)

Step 3: Review and Dispute calendar year 2014 Data by May 20, 2015

Additional Resources