Under the Physician Payments Sunshine Act, physicians have the right to review and dispute data about them submitted through the Centers for Medicare & Medicaid Services (CMS) Open Payments system prior to public posting of such data on Sept. 30, 2014. The data cover payments made by applicable manufacturers and group purchasing organizations (GPOs) from Aug. 1–Dec. 31, 2013.

Physicians and teaching hospitals have until Aug. 27 to review and initiate any disputes regarding the data reported about them. Industry has from Aug. 28 to Sept. 11 to submit corrections to disputed data. Erroneous information not corrected by Sept. 11 will be included in the reports made available to the public on Sept. 30.

CMS recommends that physicians take the following steps:

• Register in the CMS Enterprise Portal (https://portal.cms.gov) and then in the Open Payments system (https://go.cms.gov/openpayments). Registration in the Enterprise Portal requires identity verification and may take some time. Registration for the Open Payments system will take about 30 minutes and must be finished in a single session; entries cannot be saved or completed at a later time. The system times out after 15 minutes of inactivity and does not have an auto-save feature. CMS recommends using only Internet Explorer version 8 or later to register for the Open Payments system. CMS also cautions against using a browser’s navigation buttons, which can delete registration data.
• Delegate roles and responsibilities by nominating staff members or others to fill specific user roles (individuals who can interact with the Open Payments system on behalf of the physician).
• Gather any records of payments, transfers of value, ownership, or investments received between Aug. 1, 2013, and Dec. 31, 2013.
• Ask local industry representatives if their organization has reported data about you to CMS; if so, ask for a copy.
• Review and dispute data submitted by applicable manufacturers and GPOs before Aug. 27, 2014. Any disputed data that are not corrected by industry will be marked as disputed when they are made public.
• Organize industry contact information; physicians must work directly with industry to resolve any disputes or answer any questions about reported data.

For questions, contact the CMS help desk at 855-326-8366 or openpayments@cms.hhs.gov