Physician Payment Sunshine Act

Register now – March 31, 2015 is the deadline to submit corrected data from 2013 and submit 2014 data to the Open Payments System.

AES Responds to Proposed CME Rules in Sunshine Act

Industry Reported Data 

Data reported by industry from 2013 was made public on September 30, 2014

Open Payments was created by the federal government with the intention of creating greater transparency around the financial relationships of manufacturers, physicians, and teaching hospitals. The program requires that the following information is reported annually to CMS:

  • Applicable manufacturers of covered drugs, devices, biologicals, and medical supplies to report payments or other transfers of value they make to physicians and teaching hospitals to CMS.
  • Applicable manufacturers and applicable group purchasing organizations (GPOs) to report to CMS certain ownership or investment interests held by physicians or their immediate family members.
  • Applicable GPOs to report to CMS payments or other transfers of value made to physician owners or investors if they held ownership or an investment interest at any point during the reporting year.


Physician and Teaching Hospital Registration in the Open Payments Opens on March 31, 2015
Starting now, physicians and teaching hospital representatives can register in Open Payments system. Visit the Physician page or Teaching Hospital page for more information.

Physicians must register in order to view the data reported on them. Registration is a multi-step process, so it is recommended to start as early as possible. While there is no official end date for when physicians need to finish the registration steps, in order to review or dispute data submitted by industry for the 2014 reporting period, physicians must be registered – and have reviewed any data reported about them by the end of the initial 45-day review and dispute period.

Dispute Resolution Process and Tracking Tools

The Open Payments review and dispute process is anticipated to begin in April 2015. The review, dispute and correction process allows physicians and teaching hospitals to review and initiate any disputes regarding the data reported about them by applicable manufacturers and applicable GPOs before CMS makes the information public later in 2015. Visit the Dispute and Resolution page for more information.

  • March 31, 2015: Manufacturers/GPOs required to report the data for 2014.
  • August- September, 2015: CMS will provide physicians access to their individualized consolidated version of all manufacturers/GPO reports for the prior calendar year in June 2014. Physicians may access the consolidated reports via an online website portal maintained by CMS and will be able to seek correction or modification by contacting the manufacturer/GPO through the portal. View the registration informaiton. Members should promptly log or register to check to assure any listing for them is correct. There will be 15 day window to send corrections and verify information before CMS makes it public.
  • September 2015: CMS will release most of the data on a public website.

Toolkit for Physician Financial Transparency Reports (Sunshine Act)

The portal is currently only for industry, but epilepsy professionals can download the CMS mobile app

Download a free smartphone app to track reportable transfers. Compatible with Apple® and Android platforms, “Open Payments Mobile for Physicians” is available through the Apple Store and Google Play® Store. A number of security features protect the privacy of the data you capture, which will be stored on one device and cannot be backed up to a cloud or other devices. Also urge your industry contacts to use the app so you will be able to capture the information you need to ensure accurate reporting.