Chief Compliance and Ethics Officer Health Care

Open Payments / Sunshine Act Monitoring

  • 1.  Open Payments / Sunshine Act Monitoring

    Posted 05-01-2019 11:03 AM
    Good morning:

    We received a letter from CMS to check the 2018 records for one of our providers, as the deadline to dispute before publication is coming up.  Is there a way for me, as the compliance officer, to have access to all our providers' pre-publication records?  Or how do other facilities monitor these payments?  We have about 60 physicians.  And, from what I recall, the SUPPORT Act has extended the "Sunshine Act" to APPs starting in 2020, so that may be up to 100 individuals that I would have to monitor(!).  I would like to be able to send print-outs to all providers and have them contact me if they need help with a dispute.

    Thank you!


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    Sophie Morgan
    Compliance Officer
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    2019 HCCA Compliance Institute