Opening Pandora's Box: The Open Payments Reporting Requirements

The Open Payments initiative is an inflection point for the pharmaceutical and medical-device industries. All applicable manufacturers have submitted summary aggregate-spend information for the 2013 reporting period, and are now focused on compiling, validating, and reporting transaction-level spend information for Phase 2 submission. As announced by the Centers for Medicare and Medicaid Services (CMS), applicable manufacturers must submit Phase 2 data between June 1 and June 30, 2014, leaving companies just 30 days to finalize seemingly countless transfers of value.

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