CMS announced that it has updated the Sunshine Act / Open Payments dataset to reflect (1) changes made to records, (2) changes to delays in publication flags, (3) changes to disputed records, and (4) deleted records. 

According to an email that CMS sent to the Open Payments listserv announcing the data refresh, the agency plans to update the published data at least once a year based on data corrections or updates to disputed data submitted by applicable manufacturers and group purchasing organizations. CMS stated that the updates relate to all types of payments or transfers of value to physicians and teaching hospitals, as well as physician ownership or investment interests.

Although CMS has provided improved tools for searching the Open Payments website (, we would be happy to discuss more efficient ways that companies can efficiently review and analyze the data outside the government’s platform, including all “refreshes” of the data.  Please contact our Sunshine Act team to learn more.