The CME Coalition has submitted comments to the Centers for Medicare and Medicaid Services (CMS) with respect to the Dispute Resolution process for Open Payments, the program to implement the Physician Payments Sunshine Act. While endorsing the manifest goals of the Sunshine Act, the Coalition recommends that CMS delay publication of the payments information to allow physicians ample opportunity to correct the record on their reported payments.
Given the fact that a doctor's reputation is easy to impugn but incredibly difficult to resuscitate, the Coalition suggests that CMS delay the publication of information for six months, rather than "run the risk of unwarranted reputational damage that has the potential to harm careers." Beyond reputational damage, the implication for those covered recipients could include anti-fraud, anti-kickback and Stark law investigations, the provision of inaccurate evidence for a tax audit, and potential violations of private employment contracts.
| CME Coalition Comments on Sunshine Act Dispute Resolution Process |
