The Centers for Medicare & Medicaid Services (CMS) issued additional information today for pharmaceutical and medical device manufacturers and group purchasing organizations (GPOs) that must register and submit data to the Open Payments system in connection with federal Sunshine reporting requirements.  Specifically, CMS announced that it has decided to implement a two-step process for registration and data submission.  Phase I, which will occur from February 18, 2014 – March 31, 2014, will allow for user registration in CMS’ Enterprise Portal, submission of corporate profile information and submission of aggregate 2013 payment data.  The corporate profile and aggregate data submission materials have not been made available on the Open Payments website and are only accessible after CMS registration is completed. 

Phase II will involve industry registration in the Open Payments system, submission of detailed 2013 payment data and legal attestation to the accuracy of the data.  Phase II will start in May 2014 and last for no less than 30 days.  Both phases will be completed by August 1, 2014, at which time health care professionals will be able to review and dispute data submissions.  CMS stated that it will provide more information regarding this process in spring 2014. CMS also stated that it will not enforce penalties for non-compliance with the Sunshine reporting requirements until after the close of Phase II for this first reporting period.   

The date and registration information for another industry-focused webinar event regarding this phased approach to registration and data submission is expected to be released by CMS next week.  We will post this information when it becomes available from CMS.

Posted by Cooley

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