Life Science Compliance Update

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May 06, 2013

Physician Payment Sunshine Act: CMS Posts Reporting Templates for 2013

CMS released their physician payment sunshine reporting templates for 2013.   The templates apply for reports August 1, 2013 - December 31, 2013. 

Final Templates 

General Payments Non Research 

Physician Ownership  


Supporting Documentation 

List of Revisions (Cross walk) 

Supporting Statement 

Reviewing the templates reveals that they have made significant changes to their templates from the proposed templates this included edits, insertions of new fields and deletions.  There were 62 pages of changes in all.               

In their Q&A section on Open Payments, CMS states that these templates will apply for 2013 reporting and they will post by October 1 the reporting templates for each subsequent year. 

According to Polaris Management, an aggregate spend consulting and software supplier some of the changes include:

Non-Research Template

  • Changes
    • Physician Specialty
      • Is now 10 digits to be in line with actual taxonomy code sizing.
    • State License Number and State Is consolidated into 1 field (from 2) and can include up to 5 pairs of data.
    • You no longer have to put the entity making the payment, for example the name of your third party vendor
  • Deletions
    • Indirect payment indicator
    • Details of Form of Payment
    • Province is no longer required internationally because not every country has provinces
  • New fields
    • Product Indicator
      • New field to categorize products
      • Values are: covered, non-covered, none and combination
    • Charity indicator
    • If the 3rd party is a covered recipient
      • Answer questions about double reporting of certain payments
    • Delay in publication
      • For items outside a study protocol that still need to be delayed 

Research Template

  • Changes
    • Non-research template changes
      • For example, specialty and state license number changes
    • Expenditure category
      • Combines category and a percentage of payment associated with that category
    • Multiple PIs
      • Ability to list out more than one tied to the same study
  • New fields
    • Name field for non-covered recipient entities
  • Removed fields
    • No more fields around payment structure items and total number of years for research


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We know what information you want us to report and in what format you need it. Please advise me on how we will be submitting that specific information. Will you be accepting paper reports? Electronic Reports? Will we be entering data into a database?

Why are your templates in PDF format? Will you be providing working templates?

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