Drug and medical device manufacturers have completed their submission of data to the Open Payments system on payments or transfers of value made to physicians and teaching hospitals during 2015. Physicians and teaching hospitals now have until May 15, 2016, to review and dispute records attributed to them. The review and dispute process is voluntary, but encouraged.

The Centers for Medicare and Medicaid Services (CMS) will publish the 2015 payment data and updates to the 2013 and 2014 data on June 30, 2016.

Under the Sunshine Act, drug and medical device manufacturers are required to report their financial interactions with licensed physicians – including consulting fees, travel reimbursements, research grants and other gifts. Any payments, ownership interests and other “transfers of value” were reported to CMS for publication in the online database.

Physicians who are not already registered should be aware that there is a two-step process to register for the Open Payments program. The first step requires physicians to register at the CMS Enterprise Identity Management System portal, a step many physicians may have already completed as the gateway enables access to a number of other CMS programs. Step two is to register in CMS’ Open Payments system.

Physicians who have already registered but have not accessed their account in the past 60 days will need to unlock their account by going to the CMS Enterprise Portal, which will prompt you to enter your user ID and correctly answer all challenge questions. You will then be prompted to enter a new password.

Users who registered last year, but who have been inactive for more than 180 days, will need to reactivate their account by contacting the Open Payments Help Desk via email or by phone at (855) 326-8366.

CMS also hosted a provider call on April 12, to help physicians understand the program and how they can review applicable data on payments or transfers of value prior to publication. To download the presentation, audio recording and written transcript of this call, click here.

Physicians and authorized representatives can also submit questions to the CMS Help Desk at openpayments@cms.hhs.gov or (855) 326-8366, Monday through Friday, from 8:30 a.m. to 7:30 p.m. (EST), excluding federal holidays.

More information on the Sunshine Act is available in the American Medical Association's online “Physician Sunshine Act Tool Kit,” which provides a variety of resources to help physicians navigate the Sunshine Act changes, including a free webinar, a list of important dates, answers to frequently asked questions, information about how to challenge incorrect reports, and ways to be more transparent with patients about the physician's interactions with the pharmaceutical and medical device industries.