According to the Sunshine Act, applicable manufacturers of covered drugs, devices, biological products, and medical supplies must report annually certain information regarding payments and other transfers of value to physicians and teaching hospitals. An additional provision requires applicable manufacturers and applicable group purchasing organizations (GPOs) to report all ownership and investment interests held by physicians or members of their families.

The Centers for Medicare and Medicaid Services (CMS) has extended the deadline for applicable manufacturers and GPOs to submit and attest to their 2014 Sunshine Act data to midnight on Friday, April 3, 2015. CMS has announced that the Open Payments system is scheduled to open for review and dispute on April 6, 2015, which will mark the start of the 45-day review and dispute process for physicians and teaching hospitals. Although the review process is voluntary, physicians and teaching hospitals must register in CMS' Enterprise Identity Management System (EIDM) and the Open Payments system prior to participating. 

CMS intends to publish the 2014 payment data and any applicable updates to the 2013 data by June 30, 2015. Prior to submitting their data, applicable manufacturers and GPOs must register or recertify their registrations in the Open Payments system.