Applicable Manufacturers Face June 30th Deadline for Sunshine Act Reporting


CMS will begin to enforce what could be significant penalties on manufacturers who fail to report required data.

The Centers for Medicare & Medicaid Services (CMS) has announced a short timeframe before detailed payment and ownership data is due and they begin enforcement of the physician payment “sunshine” provisions of the Patient Protection and Affordable Care Act and CMS’ final rule interpreting such provisions (collectively, the Act, also known as Open Payments). To avoid substantial non-compliance penalties, applicable manufacturers and group purchasing organizations (GPOs) should promptly familiarize themselves with CMS’ Open Payments system and the associated registration, reporting and attestation requirements. CMS’ May 23, 2014 announcement about “Phase 2” of the registration and reporting process provides only 30 days — from June 1, 2014 to June 30, 2014 — for final submission of 2013 payment and ownership data. As CMS previously stated that Phase 2 would last for no less than 30 days, drug and device companies have only the minimum amount of time to complete final registration, data submission and legal attestation.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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