Open Payments and COVID-19

Open Payments Review TimelineOpen Payments, also known as The Sunshine Act, is a national disclosure program that promotes a more transparent and accountable health care system by making the financial relationships between applicable manufacturers and group purchasing organizations (GPOs) and health care providers (physicians and teaching hospitals) available to the public.

CMS is aware that the COVID-19 pandemic is greatly impacting the healthcare community as a whole and understands the tireless work of its healthcare providers this time. However, due to statutory limitations, CMS does not have the authority to postpone the review and dispute period of April 1 – May 15, 2020.

The review and dispute period for physicians and teaching hospitals remains April 1-May 15, 2020. In order to complete the review and dispute process, covered recipients must register in the Open Payments system.

Covered Recipients have until December 31, 2020 to initiate disputes of data published in 2020. If a new dispute is initiated after the 45-day review and dispute window (April 1-May 15), it will be published as original attested-to data in the initial data publication.

A comprehensive list of frequently asked questions about the Open Payments program is provided on the CMS website.  These FAQs are reviewed and revised as needed in order to support the implementation of the program.