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Medicine Matters

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Medicine Matters Home Patient Care Physician Payments Sunshine Act Review and Dispute Period

Physician Payments Sunshine Act Review and Dispute Period

It is that time of year again to make you aware that we are now beginning the next cycle of the Physician Payments Sunshine Act/Open Payments, the federal law that requires manufacturers of drugs, medical devices and biologics to report to the Centers for Medicare and Medicaid Services (CMS) certain payments made to physicians and teaching hospitals. CMS expects that payments reported for calendar year 2020 will be made available to the public on or about June 30, 2021. Please be aware of the key information, below:

  • The review and dispute period is now underway, and physicians can dispute inaccurate payment information. The deadline for submitting disputes is May 15.
  • Physicians must record disputes directly in the Open Payments system, which then alerts the manufacturer. The deadline for resolution of disputes to be submitted by the manufacturer to CMS is expected to be May 30.
  • Physicians should also review reported research payments for which they are identified as a principal investigator. CMS uses its own criteria to define principal investigators, so co-investigators may be identified.

To view reported payments, you must register in the CMS Enterprise Portal and with Open Payments.  If you previously registered but have not logged in within 180 days, you should call the support desk at 1-855-326-8366 or email openpayments@cms.hhs.gov to reinstate the account.

You can find additional instructions and FAQs on the CMS website. Please also check the Office of Policy Coordination’s website for updates.

If you have questions, please email the Office of Policy Coordination at sunshine@jhmi.edu. Voicemails may be left at 410-361-8667 and will be responded to as promptly as possible.

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Kelsey Bennett