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A bipartisan Senate bill (S. 2153) introduced this week would expand reporting obligations under the Sunshine Act / Open Payments program to cover payments or other transfers of value provided to physician assistants and nurse practitioners.   Right now, pharmaceutical and device manufacturers report on only their physician financial relationships, which could give rise to concerns that the industry will shift payments to other authorized prescribers, such as PAs and NPs.   Although these…
On schedule, CMS released the 2014 Sunshine Act data, which shows $6.49 billion in transfers of value by pharmaceutical and medical-device manufacturers to physicians and teaching hospitals.  The data covers 11.4 million financial transactions attributed to over 600,000 physicians and more than 1,100 teaching hospitals. Join us on July 8 or July 14 for a web seminar discussing the trends revealed by the 2014 data and exploring the compliance risks that affect both pharmaceutical…
Yet another set of data for your risk analysis: on April 30, 2015, the CMS released a 23-million record data set from Medicare’s Part D Prescriber Public Use File. While other CMS data sets have focused on provider remuneration (whether paid by manufacturers or Medicare itself), the Part D data focuses on physicians’ and other practitioners’ prescribing practices of drugs, which may well be linked to the Sunshine Act data showing whether a prescribing physician had…
Physicians and teaching hospitals can begin reviewing the Sunshine Act data attributed to them by applicable manufacturers on Monday, April 6. The 2014 data – the first full year of reported data –  was due on March 31.  Physicians and teaching hospitals can register in both the CMS Enterprise Portal and the Open Payments system to review the data.  According to CMS, physicians and teaching hospitals can still initiate disputes after the 45-day review period,…
Starting today, applicable manufacturers and GPOs can begin submitting data about Sunshine Act payments and transfers of value for the 2014 calendar year, according to a listserv email from CMS. Applicable manufacturers and GPOs can also submit corrected 2013 data, as needed, until the March 31, 2015 deadline for data submission. Physicians and teaching hospitals are now able to register in preparation to review any data submitted about them, for which the review-and-dispute period is…
The shifting guidance on whether the industry should report mere funding of educational events, the likely enforcement ahead by federal and state agencies, and maps showing the “hotspots” of consulting, food and beverage, and travel and lodging payments: here’s what you should know now about the Sunshine Act / Open Payments database. The indirect-payment exclusion appeared to cover more ground than we thought: With the finalized changes to the Sunshine Act regulations, CMS appeared…
CMS has finalized four revisions to the Sunshine Act (Open Payments) regulations as part of the 2015 Medicare Physician Fee Schedule Final Rule. These revisions are effective as of October 31, 2014, and will be implemented for the 2016 program year, with reporting to CMS in 2017. Importantly, CMS has removed the exclusion for continuing medical education (CME) speaker compensation from manufacturers’ transparency reports. The life-sciences industry had pushed hard for this exclusion before…
The “Open Payments” database of transactions reported under the Physician Payments Sunshine Act has launched on its scheduled release date of September 30 and is now available for public review. Pharmaceutical and medical-device manufacturers reported information about their financial relationships with physicians and teaching hospitals for the second half of 2013 to the Centers for Medicare & Medicaid Services (CMS). According to CMS’s press release, the data covers 4.4 million payments—totaling nearly $3.5 billion—attributable…
Despite extending the dispute-and-resolution deadline to account for the days that the Centers for Medicare & Medicaid Services (CMS) pulled down the reporting system, the public Physician Payments Sunshine Act website is still expected to go live in a matter of weeks. It now seems, however, that CMS will publish only two-thirds of the reported transaction data. CMS claims that the remaining third contains errors significant enough that it cannot be published. This is because…