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“Sunshine Act”

The CMS Open Payments Program, also called the “Sunshine Act”


Note: The information on this site is provided to members of the Johns Hopkins Medicine Community as a resource for the Open Payments program, which is also referred to as the “Sunshine Act”.

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Overview of the Sunshine Act and Implications for Johns Hopkins Physicians and Certain Advanced Practice Providers

The Sunshine Act requires that detailed information about payments and other “transfers of value” worth over $10 from manufacturers of drugs, medical devices and biologics to physicians and teaching hospitals be made available to the public. A physician is defined as a M.D., D.O., D.D./D.D.M., D.D.S., D.P.M., O.D. and D.C.P. who is licensed in any state in the U.S., whether or not they are practicing. Starting with the 2021 data, payments will also be reported for physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists (including anesthesiologist assistants) and certified nurse midwives (collectively referred to as advanced practice providers). 

The Act has implications for Johns Hopkins physicians and advanced practice providers who consult, serve on scientific advisory boards, receive royalties or engage in other compensated activity in a personal capacity for manufacturers of drugs, devices or biologics. Details of the compensation for these activities, including the purpose of the payment, are posted on a publicly accessible web site that is maintained by the federal Centers for Medicare and Medicaid Services (CMS).

Physicians and advanced practice providers may review and, if necessary, dispute reported payments. Individuals, not the provider’s employer, are responsible for reviewing the accuracy of reported data and submitting disputes if the data are inaccurate. The first cycle of payment data (covering payments made during the five-month period of August 1 through December 31, 2013) became publicly accessible in September 2014. Beginning in 2015, data for the previous calendar year has been published annually in June on the CMS web site. Physicians can view their previously published data by searching for their name using the Open Payments web site search tool.

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Key Dates and Important Information


In order to review and dispute reported payments, physicians and advanced practice providers must be registered in the Open Payments system. Registration is a two-step process. Individuals must first register in the CMS Enterprise Identity Management (EIDM) System and then register in the Open Payments system. 

Registration information is available here.  

For step-by-step instructions on the registration process click here.  

If you registered previously, you may be required to reset your password. Accounts are locked if there has been no activity within the past 60 days and deactivated after no activity for 180 days. CMS has specific requirements for passwords which can be found here.  

You should allow sufficient time to complete the registration process and be aware that the CMS Help Line may have limited hours.

Review and Dispute: 

Beginning on or about April 1, JHM physicians and advanced practice providers are advised to review their reported payments for accuracy and submit any disputes to Open Payments by May 15. CMS will then notify the manufacturer of the dispute. Individuals should work with the manufacturer to resolve the dispute and correct any inaccuracies by May 30. Manufacturers have generally provided contact information in Open Payments to assist in resolving disputes.  

After the pre-publication review and dispute period has closed, recipients can still dispute inaccurate payments until December 31. The dispute will not be reflected in the published data, but it will advise the manufacturer that there’s been a dispute.

Information about the review and dispute process is available here

If physicians or other providers initiate disputes regarding either (i) payments of a significant dollar amount, or (ii) a significant number of individual payments, they are asked to advise the Office of Interaction with Industry at sunshine@jhmi.edu.   

To determine whether the reported payment data are accurate, physicians and advanced practice providers are advised to maintain records of the payments they receive from manufacturers.

Research Payments: 

At Johns Hopkins, research payments are made to the institution and not to individual physician investigators. Research payments are displayed in a dedicated section of the Open Payments database. The Sunshine Act requires that manufacturers identify up to five Principal Investigators in connection with research payments made to the institution.    

Physicians are able to review and dispute their designation as a Principal Investigator in connection with institutional research payments. 

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Other Key Elements of Open Payments

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More information about the Sunshine Act is available on this CMS web site. To receive updates from CMS, physicians and advanced practice providers may register for the listserv by emailing OPENPAYMENTS@cms.hhs.gov.


​CMS procedures are subject to change and this site will be periodically updated.

Last update: November 2022.