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    CMS Open Payments Rules and Database

    The Centers for Medicare & Medicaid Services (CMS) rule, Transparency Reports and Reporting of Physician Ownership or Investment Interests, also known as the Physician Payments Sunshine Act, requires applicable manufacturers of drugs, devices, biologicals, or medical supplies to annually report to the CMS certain payments or transfers of value made to physicians or teaching hospitals. It also requires manufacturers and group purchasing organizations to disclose physician ownership or investment interests.

    • The CMS is required to publish this information on or by June 30 each year and submit an annual report to Congress. Physicians and teaching hospitals are responsible for reviewing payments and submitting disputes annually.

    • Physicians and teaching hospitals can review and dispute the payments reported about them before the data are made publicly available on the CMS Open Payments website. Registration in the CMS Identity Management System (PDF) is required to participate in review and dispute. If you have already registered, you can go directly to the CMS Portal to participate in the review and dispute process.

    • The CMS is not responsible for the facilitation of disputes. Physicians and teaching hospitals should communicate directly with reporting entities for resolution.

    • In 2021, the CMS expanded and now covers the following recipient types: physicians, teaching hospitals, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and anesthesiologist assistants, and certified nurse-midwives.

    Related AAMC and CMS Initiatives

    In 2023, the CMS Open Payments team, in consultation with the AAMC FOCI Steering Committee and AAMC staff, developed educational resources for use at institutions. These resources are designed to help educate physicians about the Open Payments program and for authorized representatives of teaching hospitals:

    AAMC Resources

    CMS Resources