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Physician Financial Transparency Reports (Sunshine Act)

Concerns have been raised about reporting requirements and participation in commercially-supported accredited and certified continuing medical education (accredited/certified CME) programs in 2016. To respond to these concerns, the AMA is providing an overview of the relevant statutory, regulatory, and sub-regulatory guidance that exempts compliant accredited and certified independent CME from reporting in the Open Payments System.


The Physician Payments Sunshine Act is designed to increase transparency around the financial relationships between physicians, teaching hospitals and manufacturers of drugs, medical devices and biologics. The Centers for Medicare & Medicaid Services (CMS) fulfills the law's mandate via the Open Payments Program.

Manufacturers now must submit annual data on payment and transfers of value made to covered recipients. Physicians have 45 days to review their Open Payments data and dispute errors before public release. If the deadline is not met, physicians can still review and dispute errors and corrections will appear in the database's next scheduled update.

Sunshine Act - Key Steps

Review Open Payments Data

Share your experiences: Please let us know how your registration goes with the Open Payments Program by sending an e-mail to OpenPayments@ama-assn.org. Responses will be used in the AMA's ongoing advocacy efforts.

Download Resources

Consult the AMA's Sunshine Act Toolkit.

Download talking points for help in responding to general inquiries about the Sunshine Act.

Ask Questions

Contact Open Payments Program help desk at openpayments@cms.hhs.gov or call (855) 326-8366.

Keep Track

CMS created a free smartphone app for Apple® and Android platforms. To protect the privacy of the captured data, information 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 can capture the necessary information to ensure accurate reporting.