The “Open Payments” database of transactions reported under the Physician Payments Sunshine Act has launched on its scheduled release date of September 30 and is now available for public review.

Pharmaceutical and medical-device manufacturers reported information about their financial relationships with physicians and teaching hospitals for the second half of 2013 to the Centers for Medicare & Medicaid Services (CMS).

According to CMS’s press release, the data covers 4.4 million payments—totaling nearly $3.5 billion—attributable to over half a million physicians and over a thousand teaching hospitals.

We invite our clients to review the data, available at, and are glad to discuss its implications.

Although CMS has provided context for the reported data—as widely recommended by physician and industry group—the data may give rise to misinterpretation, particularly in light of likely reporting inconsistencies based on unclear guidance in the Sunshine Act regulations and potential errors in the data set.

As we previously reported, CMS has already withheld significant portions of the data based on identified errors.

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