CMS Issues Phase 2 Sunshine Reporting Instructions, Deadlines

By Nick Otto

The Centers for Medicare & Medicaid Services posted instructions on completing the second phase of its 2014 reporting process under the Physician Payment Sunshine Act, providing relevant dates, instructions and other information for industry.

Beginning June 1, device makers will have until the end of the month to register, report, and attest to the accuracy of detailed data concerning each payment to physicians and teaching hospitals during the last five months of 2013.

“We are already encouraged by the high rate of preliminary industry data submission and expect a similarly high level of industry engagement when detailed data submission starts,” CMS said last week in a blog post.

Manufacturers will report the financial interactions they had with physicians and teaching hospitals between August and December of 2013, including meal compensations, travel, gifts, consulting, and research.

Phase 1 of the Sunshine Act, which ended March 31, involved just the submission of aggregate data, according to a recent blog post from Hyman, Phelps & McNamara.

“Among the newly-posted information on CMS’ site are detailed instructions for the Phase 2 submission, a Phase 2 tutorial, updated submission data mapping documents and the text of the lengthy attestations that applicable manufacturers will have to make in order to submit the required payment data,” the law firm adds.

Phase 2 will require a two-step process. In step 1, manufacturers must:

• Complete Open Payments system registration for authorized officials of applicable manufacturers and applicable GPOs and their reporting entity;
• Confirm the accuracy of the reporting entity profile data submitted for Phase 1;
• Delegate roles and responsibilities by nominating system users to fill specific user roles;
• Perform test file uploads and submit data files to validate the file structure and contents of the file; and
• Utilize the error report produced by the Open Payments system to fix any data errors (if any) in submitted files.

Following a successful upload and validation of the test data files, industry users can move to Step 2. In this final step, which will begin June 9 at the earliest, a “Final Submission” function will be available in the open payment system. There, users should perform a final data submission and attest to its accuracy.

All of Phase 2 – steps 1 and 2 – must be completed by June 30, 2014.