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Washington Highlights

CMS Announces “Sunshine” Act Database Registration Update

May 30, 2014—The Centers for Medicare and Medicaid Services (CMS) announced that on June 1 physicians and teaching hospital delegates may register in the CMS Enterprise Portal to eventually review reported payments made by drug and device manufacturers.

Registration in the Enterprise Portal is the first of a two-step process that must be completed to access information in the CMS “Sunshine” database, Open Payments, established under the Affordable Care Act (P.L. 111-148 and P.L. 111-152). After establishing their identity in the CMS Enterprise Portal, physicians and teaching hospital delegates will still need to register in the Open Payments system to access to records reported by manufacturers.

Registration in Open Payments is not yet available.

In the Open Payments system, physicians and teaching hospital delegates will have access to their related records for a 45-day review window.  Disputed records need to be resolved within that 45 days or a 15-day resolution period for any changes to be made to the information. The resulting database is scheduled to be made publically available by Sept. 30, 2014.

The final Sunshine rule, “Transparency Reports and Reporting of Physician Ownership or Investment Interests,” requires manufacturers of drugs, devices, biologicals, and medical supplies to report annually to CMS any payments or transfers of value made to physicians and teaching hospitals. Under the final rule, those manufacturers were required to report to CMS all payments or transfers of value made to physicians or teaching hospitals between Aug. 1 and Dec. 31, 2013  [See Washington Highlights, Feb. 8, 2013].

CMS first published the proposed rule in the Dec. 19, 2011, Federal Register. The AAMC submitted a Feb. 17 letter to CMS in response to a request for comments on the proposed rule [See Washington Highlights, Feb. 24, 2011].

CMS has requested comments by June 2, 2014, on the proposed dispute resolution and corrections process through a notice of Agency Information Collection Activities published in the May 5 Federal Register.  The AAMC plans to submit a comment letter.


Heather Pierce, JD, MPH
Sr. Director, Science Policy & Regulatory Counsel
Telephone: 202-478-9926


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806