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'Transfer of value' reports to go public Sept. 30

Dentist review-dispute period ends Aug. 27

July 28, 2014

By Craig Palmer

Washington – Dentists have until Aug. 27 to register to review and dispute Sunshine Act reports that the government will post on a searchable public Open Payments website beginning Sept. 30.

The Sunshine Act requires certain companies that provide payments, gifts, food, education and other "transfers of value" to dentists to report information to the government about each dentist and what was provided and to report ownership and investment interests held by dentists and their immediate family members.

Physicians, including dentists, and teaching hospitals can register in the Open Payments system to review and dispute data submitted by applicable manufacturers and applicable group purchasing organizations during the first phase of a review, dispute and correction process that ends on Aug. 27. From Aug. 28 through Sept. 11 industry "will analyze these disputes and work with physicians and teaching hospitals to come to agreement on any necessary corrections," said the Centers for Medicare & Medicaid Services.

The ADA has prepared Frequently Asked Questions to help members understand the implications of the Sunshine Act. The members-only FAQ covers these questions:

  • What is the purpose of the Sunshine Act?
  • Which providers are affected by this program?
  • Do dental practices have any reporting requirements?
  • Is there a minimum dollar amount, or will every payment and transfer be reported?
  • Which companies are required to report?
  • What information will be included in a report?
  • Are "indirect" payments and transfers of value reportable?
  • How can a dentist keep track of payments and other transfers from companies?
  • How can a dentist find out that a report has been filed?
  • What can a dentist do if a report is inaccurate?
  • How much time does a dentist have to review a report before it is made public?
  • What if a dentist and the company are not able to resolve a dispute?
  • When do the data collection and reporting begin, and when do the reports become publicly available online?
  • What are the penalties for noncompliance?
  • What is meant by an "immediate family member" for purposes of reporting ownership and investment interests?
  • What are some things a dentist can do if a company says that a payment or transfer will be reportable?
  • What are some of the exceptions to the reporting requirement?
  • Are payments and transfers of value for research reportable?
  • If a company makes an indirect payment or transfer to me through my dental society, will my dental society have any reporting obligations? Will my dental society be asked to provide information about me to the company?
  • Where can I find out more about the Sunshine Act and the Open Payments website?
  • How can I help my patients better understand information about my dental practice on Open Payments?