By September 30, 2014, the Centers for Medicare and Medicaid Services (CMS) will begin publishing data on financial relationships between drug and device manufacturers and health care providers. CMS will report payments to physicians and teaching hospitals, as well as physicians’ ownership interests in drug and device manufacturers or group purchasing organizations (GPOs). The information will be publicly available online and in a searchable format.

This program, which CMS calls the “National Physician Payment Transparency Program” or “Open Payments,” is more commonly known as the Sunshine Act. It is intended to increase transparency in response to public concern about conflicts of interest in patient care and research. Physicians should be aware of the information that will be reported so that they may maintain records in case of disputes, prepare for or avoid any reputational damage, and address compliance risks. There are legal and pragmatic implications.

Information Reported

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