According to the Sunshine Act and its implementing regulations, applicable manufacturers, applicable group purchasing organizations (GPOs), covered recipients, and physician owners or investors must have an opportunity to review and submit corrections to the data submitted pursuant to the Sunshine Act. This review and correction period must occur at least 45 days before the Centers for Medicare and Medicaid Services (CMS) makes the submitted data available to the public.
On July 11, 2014, CMS announced that the review and dispute process will begin today, July 14th, and will end on August 27, 2014. During this initial 45-day period, physicians and teaching hospitals may "review and initiate any disputes they may have regarding the data reported about them by applicable manufacturers and applicable GPOs." CMS has also allotted an additional 15 days (August 28 – September 11, 2014) to allow applicable manufacturers and applicable GPOs to continue submitting dispute corrections.
If physicians and teaching hospitals wish to participate in the dispute, review, and correction process, they must be registered with CMS. Open Payments registration for physicians and teaching hospitals began on June 1, 2014, and will be completed in two phases. Phase 1 includes user registration in CMS' Enterprise Portal. Phase 2, which begins today, July 14th, includes physician and teaching hospital registration in the Open Payments system, and will allow them to review and dispute submitted data.