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Open Payments Sunshine Act Review and Dispute Period Now Underway

The next cycle of the Open Payments Program/Sunshine Act has begun. This is the federal law that requires manufacturers of drugs, medical devices and biologics to report to the Centers for Medicare & Medicaid Services (CMS) certain payments made to physicians, teaching hospitals, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists (including anesthesiologist assistants) and certified nurse midwives (collectively referred to as covered recipients). CMS expects that payments reported for calendar year 2023 will be made available to the public on or about June 30 of this year. Please be aware of the key information, below:

  • The review and dispute period is now underway for all covered recipients of payments to dispute inaccurate information reported by manufacturers. The deadline for submitting disputes is May 15. 
  • Disputes must be recorded 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.
  • Researchers 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 on 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 855-326-8366 or email to reinstate the account.

You can find more instructions on the CMS website. Please also check interaction with industry for additional information.

Questions may be sent to Voicemail messages may be left at 667-208-8950 and will be responded to as promptly as possible.


Kelsey Bennett

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