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Sunshine Act: CMS Open Payments Program Requirements

Sunshine Act

The “Sunshine Act,” a provision of the Affordable Care Act, requires that manufacturers of drugs, medical devices and biologics collect information about payments to teaching hospitals and physicians who are licensed in any state in the United States, and report them to CMS.

The “Sunshine Act” has implications for those who receive “transfers of value” from industry, including some meals at educational events that are supported by industry, as well as consulting fees, honoraria, and/or other compensation.

During the months of August 1, 2013 through December 31, 2013, industry collected data on gifts or other transfers of value to physicians, and reported these to CMS.  Thereafter, data will be updated regularly.

Important Dates for 2018 Reporting Year


CMS Enterprise System

Register in the CMS Enterprise Portal System to review any payment or “transfer of value” reported from industry in 2018 (this includes honorarium for speaking, consulting, travel reimbursement, royalty payments, etc.). This registration will allow you to receive Open Payments Email Updates about data that may have been submitted for you for the 2018 calendar year.

Review Data

Plan to review reported data between April 1st and May 15, 2019, and dispute any inaccurate reports during this time.

Final Data

Final Data for 2018 will be reported on the CMS public website on June 30, 2019.

Contact CMS Open Payments Helpdesk or call 1-855-326-8366


U.S. Centers for Medicare & Medicaid (