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Physician Financial Transparency Reports (Sunshine Act)

The Physician Payments Sunshine Act 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. The Centers for Medicare & Medicaid Services (CMS) has been charged with implementing the Sunshine Act and has called it the Open Payments Program.

As part of this program, manufacturers now are required to submit reports on payment, transfer and ownership information.

Reports on 2013 data are being released to the public Sept. 30. Be prepared for inquiries from the media, your patients and your friends:

  • Know what is reported about you. If you have not already completed the three-step registration process to review your data, you should do so now (see key steps and dates below). 
  • Be ready for questions by providing context on the reported items. Download customizable talking points to use in your conversations with the media, patients and friends.

Questions? E-mail CMS' Open Payments Help Desk at openpayments@cms.hhs.gov or call (855) 326-8366.

Share your experiences: Please let us know how your experience is with registering in the Open Payments System by sending an e-mail to OpenPayments@ama-assn.org. Your responses will be used in the AMA's ongoing advocacy efforts.

Get additional #SunshineTips: Look up this hashtag on Twitter for pointers about the registration and review process, including insights from fellow physicians about navigating the system’s quirks.

Sunshine Act - Key Steps

Step 1: Complete CMS e-verification process today

You must complete CMS' e-verification process via the CMS Enterprise Portal (EIDM) to begin the review and dispute process.

Step 2: Register with CMS' Open Payments system

Once you have completed Step 1 and gained access to EIDM, you can register in CMS' Open Payments System via EIDM.

Step 3: Review and dispute data by Dec. 31*

You can request your individual report, review it and flag disputes after completing Step 2. CMS has indicated that it will not resolve disputes, but errors can be reported to manufacturers through the Open Payments System or directly through Open Payments contacts listed on most manufacturer websites.

*The deadline for initiating disputes and having potentially erroneous data flagged in the initial public release has passed, but you still can initiate disputes of 2013 data until Dec. 31. However, these disputes will not be flagged in the public database until 2015.

Where can physicians find answers to additional Sunshine Act questions?

To learn more about what is being reported, who has to report, what categories are being reported and more, visit the AMA's Sunshine Act Frequently Asked Questions Web page. The AMA's full Sunshine Act toolkit also provides more in-depth information. You can also access a printer-friendly Sunshine Act brochure, and talking points to help you respond to general inquiries about the Sunshine Act.

What is the AMA's policy on the Sunshine Act and related advocacy?

Access the AMA's full Sunshine Act toolkit for information on the AMA's position on the Sunshine Act and related advocacy.

How can physicians keep track of payments and financial transfers?

Download a free smartphone app to track reportable transfers. Compatible with Apple® and Android platforms, "Open Payments Mobile for Physicians" is available through the Apple Store and Google Play® Store. A number of security features protect the privacy of the captured data, which will be stored on one device and cannot be backed up to a cloud or other devices. Physicians should also urge their industry contacts to use the app so they will be able to capture the necessary information to ensure accurate reporting.

AMA Wire coverage of Sunshine Act advocacy, process and deadlines