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 Open Payments program is a national disclosure program that promotes a more transparent and accountable health care system. Open Payments houses a publicly accessible database of payments that reporting entities, including drug and medical device companies, make to covered recipients like physicians.
The majority of the information contained in the reports is available on a public, searchable website. Physicians have the right to review their reports and to challenge data that are false, inaccurate, or misleading.
CMS does not comment on what relationships may be beneficial or potential conflicts of interest. CMS publishes the data as attested to by reporting entities. The data is open to individual interpretation.
Key Dates
FEB 1 - MAR 31
Data Submission for Calendar Year (Note: This refers to the previous calendar year’s data submitted during this annual window)1
APR 1
Physician and Teaching Hospitals Review and Dispute Period Begins
MAY 15
Final Day for Physicians to Initiate Disputes
Final day for physicians to initiate disputes of erroneous data from the calendar year 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.
JUN 30