Resources for Physician Payment Sunshine Act

On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) issued its long-awaited final rule regarding the implementation of section 6002 of the Patient Protection and Affordable Care Act (ACA). The final rule, titled Transparency Reports, and Reporting of Physician Ownership or Investment Interests, also known as the “Physician Payment Sunshine Act,” or OPEN PAYMENTS, requires drug and device companies to report certain payments, ownership and investment interests, and other transfers of value made to physicians or teaching hospitals.

Applicable manufacturers and group purchasing organizations (GPOs) must begin to collect the required data on August 1, 2013 and report the data to CMS by March 31, 2014. CMS will publish the data on a searchable website by September 30, 2014.

Information to assist AACE members in understanding the new law are listed below. These resources will continue to be updated as new information becomes available.


  • Start date for collection of information - August 1, 2013
  • Physician registration for CMS Review Site MUST REGISTER TO VIEW AND DISPUTE REPORTS – January 1, 2014
  • Manufacturer report date to CMS - March 31, 2014
  • CMS to provide physicians with consolidated version of previous year’s manufacturers/GPO’s reports – August 2014 and by mid-August every year thereafter
  • CMS publication date - September 30, 2014 and June 30th in future years

Sunshine Act Final Rule
CMS Sunshine Act Press Release
CMS Fact Sheet for Physicians
Template for Transparency Reports and Reporting of Physician Ownership or Investment Interests
CMS Sunshine Act Slide Presentation
CMS Email Box for Questions Regarding the Sunshine Act
Sunshine Act FAQ Sub-Page
List of Covered Teaching Hospitals
Listing of CMS Hosted OPEN PAYMENTS Events

"WHAT YOU SHOULD KNOW ABOUT THE PHYSICIAN PAYMENT SUNSHINE ACT" by R. Mack Harrell, MD, FACP, FACE, ECNU – From the April/May 2013 The First Messenger
"AACE Sunshine Act Fact Sheet"
"AMA Summary of State Sunshine Laws"
AMA Sunshine Act Webinar (free registration required)
ACCME Accredited Sunshine Act CME Course (Medscape login required)
Sunshine Act – Effect on Physicians from New England Journal of Medicine from New England Journal of Medicine
Information on the National Physician Payment Transparency Program: OPEN PAYMENTS from MLN Matters
The Sunshine Act to begin Aug 1: Steps to take now


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