Deadline Approaches for CMS Open Payment Registration

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As discussed in a previous article, specific deadlines related to the Physician Payment Sunshine Act are approaching.  The Physician Payment Sunshine Act is a national transparency program in which certain manufacturers of drugs, devices, biologicals, and medical supplies and government purchasing organizations (“GPOs”) are required to disclose certain financial relationships with teaching hospitals and physicians.

The Phase 2 deadline is June 30th for applicable manufacturers and GPOs.  As required under this law, manufacturers of covered products and entities under common ownership with those manufacturers must, on an annual basis, report payments or other transfers of value made to teaching hospitals and physicians. Further, GPOs are required to report payments or other transfers of value made to physician owners or investors.

The Phase 2 deadline allows applicable manufacturers and GPOs to complete registration for themselves and their reporting entity, confirm the accuracy of the data submitted, and to delegate roles for users.  It is worth noting that both physicians and teaching hospitals should ensure they are registered prior to July 1st to ensure they receive the full 45 days to review any information submitted by applicable manufacturers and GPOs.

If you have any questions regarding the registration process or the compliance issues related to the Sunshine Act, feel free to contact Alex T. Krouse at (574) 485-2003 or Susan E. Ziel at (612) 564-1927 or.