Right now, medical device manufacturers, pharmaceutical companies and group purchasing organizations (GPOs), as well as ownership and investment entities, are collecting and preparing to report all payments, gifts and transfers of $10 or more that have been made to physicians.
|Key dates to keep in mind
- Aug. 1 – Dec. 31, 2013: Manufacturers are required by law to collect and track payments to physicians.
- Jan. 1, 2014: Physicians can begin registering to receive report notices from CMS.
- March 31, 2014: This is the deadline for manufacturers and GPOs to submit data for 2013 to CMS.
- June 2014: Physicians may review reports online and seek correction or modification by contacting the manufacturer or GPO.
- Sept. 30, 2014: CMS will release reports to the public.
Manufacturers must report this information to the Centers for Medicare & Medicaid Services (CMS) as required by the National Physician Payment Transparency Program or the Sunshine Act. By September 2014, the data will be available online to the public. The purpose of the law is to provide transparency in physician pharmaceutical relationships.
Reportable items include:
- Stock, stock options
- Food and beverage
- Charitable contributions
- Travel and lodging
Find a complete list here.
How you can prepare
While you are not required to report information, protect yourself by making sure manufacturers submit correct information about you.
- Keep records of all payments/transfers you receive and be proactive.
- Ask industry representatives to let you review the information they intend to report.
- Make sure you are registered with CMS by January 2014 to receive notification when information is submitted. This will give you the opportunity to review, challenge and correct reports 45 days prior to publication.
- Verify that your information in the National Provider Identifier database is current because it will be used in the report.
- If you hold any ownership interests in a manufacturer or GPO, check the information that is reported.
If you believe the report is inaccurate, misleading or false, follow these steps:
- Contact the appropriate manufacturer or GPO.
- If a dispute is not resolved, you have an additional 15 days before the report is made public to solve the issue.
- If resolution is still not reached, the report will be flagged on the public website.
You can file a dispute for two years after reports become available.
Find a helpful toolkit at the AMA website.
Also, CMS offers two smartphone apps to help you track payments and reportable financial ties. Read more at the CMS website.