When is the deadline to file disputes regarding Sunshine Act inaccuracies?

Q: When is the deadline to file disputes regarding Sunshine Act inaccuracies?

A: CMS will post the information that industry is required to provide under the Sunshine Act, on the Open Payments public website, which will be accessible to anyone on Sept. 30, 2014. Physicians should register on the open payment site and review their data for accuracy.

If you find incorrect data, you have until  Sept. 27, 2014 to file a dispute.

Beginning in August 2013, dermatologists should have begun to keep a list of all payments they receive, disclose the companies they receive them from as required, and document for their own records details about services rendered.

To aid in this effort, CMS has established a help desk for physician inquiries. Physicians may email their questions to openpayments@cms.hhs.gov. CMS also has developed a free app that physicians may use to track this information on their mobile devices. Information about how to download the app on Android and Apple devices is available here.

Register for Open Payments

Dermatologists should register with CMS so they can review their payment data for accuracy. The site includes registration instructions. Physicians can register starting June 1.

Note: Physicians may encounter significant delays when registering for the Open Payments site. Additionally, once registered, physicians may receive an error message if there is no information published about the physician. To confirm there is no information to review or to report problems with the site, physicians are encouraged to email openpayments@cms.hhs.gov.

Dispute inaccuracies

Physicians will have a 45-day period in which to review the data before it goes public and dispute any inaccuracies. Dermatologists should verify their information in the National Plan and Provider Enumeration System (NPPES) to ensure they are being identified correctly.

Physicians will need to work with the applicable manufacturer or group-purchasing organization to make corrections. After the initial 45-day period, the manufacturers will have an additional 15 days to submit corrections. If the dispute is not resolved on or before the 15-day period, CMS will publish the information but will label it as disputed.

Note: It is important for physicians to review and dispute any inaccuracies in the Open Payment data to ensure that the physicians' relationships are not misrepresented to the public.

Review information from the Academy about Medicare enrollment and documentation here.

Open Payments reporting timeline 
Data collection began. Aug. 1, 2013 
Participants can sign up for CMS’s Open Payments website.  January 2014
Data from pharmaceutical companies from August 2013 to December 2013 is due to CMS.  March 31, 2014 
Physicians can register on the CMS Open Payments website.
June 1, 2014
Deadline for physicians to file disputes  Aug. 27, 2014 
CMS to make data public.  Sept. 30, 2014 


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