Open Payments (Sunshine Act)

Subject: Open Payments and the “Sunshine” provisions of the Affordable Care Act

• The “Sunshine” provisions in Section 6002 of the Affordable Care Act require the establishment of a transparency program, now known as “Open Payments. The program increases public awareness of financial relationships between drug and device manufacturers, group purchasing organizations and certain health care providers.
• Open Payments require applicable drug and device manufacturers and group purchasing organizations to report payments or other “transfers of value” they make to physicians and teaching hospitals to Centers for Medicare & Medicaid Services (CMS).
• Reportable payments may fall in one of a number of types of payments, including consulting fees, compensation for services, honoraria, gifts, entertainment, food and beverage, travel and lodging, education, research, charitable contributions, royalty or license, current or prospective ownership or investment interest, compensation for serving as faculty or speaker, grants, and space rental or facility fees.
• By September 30, 2014, CMS will publish the reported data on a publicly available website. Drug and device manufacturers must have begun collecting the required data on Aug. 31, 2013, and were required to report the collected data through December 31 to CMS by March 31, 2014.
• At Loma Linda University Health, we support the provisions of the law regarding transparency in how we conduct business.
• Our organization has a process in place to be transparent in how we conduct business. We encourage our physicians and employees to review and be familiar with our processes and procedures.
• Please communicate with your department director or manager if you have questions or need clarification.

Questions? Please contact the Loma Linda University Health Office of Compliance at ext. 14200.

If you are contacted by news media regarding this subject, please call the Office of Public Relations at ext. 44111 during business hours, or call the Operator and ask to page the Media Relations specialist on-call at any time.

About Loma Linda University Health: Loma Linda University Health includes Loma Linda University's eight professional schools, Loma Linda University Medical Center's six hospitals and more than 800 faculty physicians located in the Inland Empire of Southern California. Established in 1905, Loma Linda University Health is a global leader in education, research and clinical care. It offers over 100 academic programs and provides quality health care to 40,000 inpatients and 1.5 million outpatients each year. A Seventh-day Adventist organization, Loma Linda University Health is a faith-based health system with a mission "to continue the teaching and healing ministry of Jesus Christ."