CMS Announces Dates for Sunshine Payment Review, Dispute & Correction Process

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The Centers for Medicare & Medicaid Services (CMS) announced today that the Open Payments review, dispute and correction process will begin on Monday, July 14, 2014 and continue through September 11, 2014.  Under the Sunshine Act final rule, physicians and teaching hospitals have the ability to review and dispute payments and other transfers of value that pharmaceutical, biotechnology and medical device manufacturers and group purchasing organizations (GPOs) recently reported to CMS, before CMS publicly discloses this information by September 30, 2014.  Specifically, physicians and teaching hospitals can review and dispute payments from July 14 through August 27, and manufacturers and GPOs have an additional 15 days, until September 11, to submit corrections. Registration by physicians and teaching hospitals in the CMS Enterprise Portal and Open Payments system is voluntary, but must be completed if physicians wish to review and dispute any information before public disclosure by CMS.  Because this registration process can take some time, physicians and teaching hospitals are encouraged to start the process as soon as possible.

 

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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