Physicians and teaching hospitals that want the chance to review information about payments or other transfers of value they’ve received from pharmaceutical, medical device and other industry groups before this information is made public should register with the Centers for Medicare and Medicaid Services (CMS) starting Sunday, June 1, 2014.

CMS’s Open Payments Program is the administration's system for complying with the provisions of the Physician Payments Sunshine Act, which was made law as part of the Patient Protection and Affordable Care Act’s passage.

Physicians and teaching hospitals are not required to register or report any information themselves. All information reporting is done by the industry groups making payments and other transfers of value to physicians and teaching hospitals — as well as group purchasing organizations that must disclose physician ownership interests. However, CMS is encouraging physicians and teaching hospitals to be involved in monitoring what is reported about them and ensuring this information is accurate before it is made visible to patients, the press and the public in late September.

Registration is a two-step process. Step one is an initial registration in CMS’ Enterpise Portal beginning June 1. The portal is the gateway to CMS’ Enterprise Management system.

Then, starting in July, physician and teaching hospital will be able to register in the Open Payments system itself. This will allow them to review and dispute data submitted by applicable manufacturers and applicable group purchasing organizations prior to public posting of the data.

Physicians and teaching hospitals will have 45 days to review and dispute their data and then an additional 15 days to resolve the disputes. In cases where the industry or group purchasing organization maintains that it didn’t make a mistake and its information is correct, the data will still be released to the public, but it will be marked as disputed.

The CMS website has links to a variety of resources on Open Payments, including details on what types of information will be reported, an app to help physicians track payments, and even online tutorials on the system that qualify for continuing medical education (CME) credits.

In addition, American Medical Association (AMA) members can access resources on its Sunshine Act information web page, including the AMA's top tips for ensuring accurate information is reported.