As previously reported, the Centers for Medicare and Medicaid Services (CMS) has adopted a two-phased approach for registration and submission of Sunshine Act data for the 2013 reporting year. Phase 1 began on February 18, 2014, and concluded on March 31, 2014. Phase 2 began on June 1, 2014, and concluded yesterday, June 30, 2014.
Since announcing this two-phased approach, CMS has consistently noted that for the 2013 reporting year it will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission. Late yesterday, however, CMS sent a notice via email stating that it will not enforce penalties for reporting non-compliance until after July 7, 2014. The message was not sent to the full CMS Open Payments listserv, and as of the time of this InfoCenter posting, CMS had not updated its website or otherwise made this notice public.