Phase 2 Sunshine Reporting Information Released By CMS

By Alan M. Kirschenbaum –

CMS has posted relevant dates, instructions and other information regarding “Phase 2” of the 2014 reporting process under the Physician Payment Sunshine Act.  (Background on this law and the 2014 reporting process can be found here.)  CMS announced that Phase 2 of the Open Payments data submission, during which applicable manufacturers will report, and attest to the accuracy of, detailed data concerning each payment to physicians and teaching hospitals during the last five months of 2013, will begin on June 1 and end at close of business on June 30.  (Phase 1, which ended on March 31, involved the submission of aggregate data only.)

Among the newly-posted information on CMS’ Open Payments web site are detailed instructions for the Phase 2 submission, a Phase 2 tutorial, updated submission data mapping documents (i.e., templates), and the text of the lengthy attestations that applicable manufacturers will have to make in order to submit the required payment data.  These materials and other information can be found on CMS’ Open Payments website here.