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Act now to protect yourself under the Physician Payment Sunshine Act



January 02, 2014
Area(s) of Interest: Advocacy 

By taking four easy steps now, you can make sure you're prepared when it's time to review your 2013 financial data before it's published online later this year.


Under the Physician Payments Sunshine Act, drug and medical device manufacturers started tracking their financial interactions with licensed physicians – including consulting fees, travel reimbursements, research grants and other gifts – beginning Aug. 1, 2013. Any payments, ownership interests and other “transfers of value” will be reported to the Centers for Medicare & Medicaid Services (CMS) for publication in an online database to be launched in the fall of 2014.


Here are four easy steps you can take now to support the accuracy of this data:


1. Make sure your disclosures are up to date. Financial and conflict-of-interest disclosures required by employers, advisory bodies and entities funding research should be updated regularly so it is consistent with the data that eventually will be publicly reported under the Sunshine Act.


2. Confirm that your National Provider Identifier (NPI) information is current. The information tied to your NPI, including your specialty, must be accurate to help ensure appropriate attribution of payments and other transfers of value that will be listed in CMS's online database.


3. Request ongoing notification from your industry contacts about the data they report to CMS. Ask your representatives at the manufacturers and group purchasing organizations with which you interact to give you an opportunity to review and correct information they intend to submit before they transmit it to CMS. The 2013 data is due March 31.


4. Track your payments and financial transfers. Download a free smartphone app to track reportable transfers. "Open Payments Mobile for Physicians" is available through the Apple Store and Google Play® Store. A number of security features protect the privacy of the data you capture, which will be stored on one device and cannot be backed up to a cloud or other devices. Also urge your industry contacts to use the app so you will be able to capture the information you need to ensure accurate reporting.


Visit the AMA Sunshine Act physician toolkit to learn more about the law's timeline, the kinds of financial interactions that must be reported and the process to challenge false, inaccurate or misleading reports.

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