Physician registration is completely voluntary but this is the only way to review and possibly dispute the data submitted about you before it is made public on September 30, 2014. This affects any actively licensed doctors of medicine, osteopathy, podiatry, optometry, dental medicine or dental surgery practicing dentistry and chiropractors. This does not depend on the physician’s enrollment in federal healthcare programs and does not apply to any residents.  The reporting period for the applicable manufacturers and group purchasing organizations (GPO’s) ended March 31, 2014.

There is a 2-step process for physicians to register in order to review any of this data (Aug 1- Dec 31, 2013) submitted by applicable manufacturers and GPO’s.  Phase 1 is underway to register for CMS’ Enterprise portal which is the gateway to access CMS’ Enterprise Identity Management system. Phase 2 will begin in the next few weeks. CMS recommends completing the registration process as soon as possible due to the potentially prolonged verification of identity process and to maximize the 45–day review and dispute period.  An additional 15 days will be granted for a dispute and possible correction of any submitted data.  If the industry does not correct the disputed data, the information will still be made public but noted as disputed.  Even after the data is made public, the physician will have 2 years to dispute the information

The Physician Payments Sunshine Act Open Payments program provides transparency of any financial interactions between physicians or hospitals with any applicable manufacturers of covered biologicals, pharmaceuticals, medical devices and supplies that participate in federal healthcare programs and any ownership or investment interests in group purchasing organizations.  In addition to the physician identifying information, the form of payment, reason for the payment, any contextual information and if applicable the specific covered device, pharmaceutical, supply or biological should be reported for:

Consulting fees

Speaker fee/honoraria for event other than certified accredited CME

Gifts and entertainment

Food and beverage

Travel and lodging



Charitable contributions


Rental space/fees

Current or prospective ownership or investment interest

Any indirect payment that manufacturer or GPO requires, instructs, directs or causes an intermediary to provide payment or transfer of value to a physician.

The following are exempt from reporting:

Certified and accredited CME tuition (excluding travel/lodging)

Honoraria to faculty from manufacturer for grant supporting education activity if certified accredited CME, not a specified faculty and not directly paid

Buffet meals, snacks, soft drinks or coffee in large scale conference setting

Product samples for patient use

Educational materials for patients (excludes textbooks)

Short -term trial of medical device

Replacement of covered device under warranty

Transfer of anything of value when physician is a patient


Items used for charity care

Any dividend in publicly traded security or mutual fund 

Sunshine Act