After two program implementation delays, mandatory reporting under the Physician Payment Sunshine Act, now known as Open Payments began on August 1, 2013. The Open Payments program is a provision under the Affordable Care Act which requires disclosure of transfer of value such as payments, gifts and investments made by medical device manufacturers and drug companies to physicians.
Reporting Requirements and Exceptions: Note: physicians are not required to report data to CMS under the Open Payments program – data reporting requirements are in place for pharmaceutical companies and medical manufacturers who transfer value to physicians. A complete list of transfers of value that require reporting to CMS can be found in the Open Payments Fact Sheet for physicians
Program Timeline: The Centers for Medicare & Medicaid Services (CMS) will be collecting data for the period of August 1 – December 31, 2013. The deadline for manufacturers to report the first five months of data is March 31, 2014. CMS will provide an opportunity to review submitted data prior to ultimately making it available to consumers as early as September 2014. Subsequently, data will be collected and reported publically on an annual basis.
Take Action: Review the CMS Open Payment website for physicians for program details. Though CMS does not require physicians to submit data, CMS encourages all physicians to track their own interactions with manufacturers and has created an App designed for this purpose. The free App, called Open Payments, can be downloaded on the iTunes store.
