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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.

Reviewing Your Data


CMS Enterprise System

Register in the CMS Enterprise Portal System to review any payment or “transfer of value” reported from industry (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.

Review Data

It's important to review your data prior to it being published so that the public doesn't see incorrect information about you. You can review and dispute data at any time. However, starting in April of each year, you'll have 45 days to review the data about you in advance of the June 30th final publication.

The drug or device company has 15 additional days after the 45 day review period to fix any disputed records.

Final Data

Final Data for the prior calendar year will be published and available to the public on the Open Payments website on June 30th (i.e. 2022 data will be published on June 30, 2023).

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


U.S. Centers for Medicare & Medicaid (