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Open Payments

Frequently Asked Questions about Cook Medical's approach to Open Payments (US Physician Payments Sunshine Act)

Collaboration with physicians to develop innovative advancements in medical treatments has been an important part of our history at Cook Medical. For more than 50 years, physicians have worked with us to develop products, conducted clinical trials on our products, and helped us with product training for other healthcare professionals.

Laws have been created in the United States to encourage transparency in the relationships between physicians and industry. The 2010 US Physician Payments Sunshine Act, now more commonly called Open Payments, required that in 2013 we begin tracking our financial interactions with physicians and teaching hospitals. Annually, the financial information is reported on a public, government website by the Centers for Medicare & Medicaid Services (CMS).

See below for answers to commonly asked questions that physicians have about Cook’s approach to Open Payments. See the box on this page for more information about Open Payments.

What is Open Payments and why was it enacted?

Open Payments (also known as the Sunshine Act) requires that medical device, pharmaceutical, biological, and medical supply manufacturers report certain transfers of value made to physicians and teaching hospitals.

This legislation was introduced by Senator Grassley (R) and Senator Kohl (D) and became law as part of the 2010 Patient Protection & Affordable Care Act.

One goal of the law is to increase transparency regarding the extent and nature of relationships between physicians, teaching hospitals, and industry manufacturers to help patients make better-informed decisions when choosing healthcare professionals and making treatment choices.

Another goal is to deter the kind of financial relationships that can sometimes lead to increased healthcare costs.

Who is affected by Open Payments?

Covered recipients:
US-licensed physicians, including the following even if they are not currently practicing:

  • Doctors of medicine or osteopathic medicine
  • Doctors of dental medicine or dental surgery
  • Doctors of podiatric medicine
  • Doctors of optometry
  • Chiropractors
  • Fellows (but not residents)
  • Advanced practice providers*
    • Physician assistants
    • Nurse practitioners
    • Clinical nurse specialists
    • Certified registered nurse anesthetists
    • Anesthesiology assistants
    • Certified nurse-midwives
  • US-based teaching hospitals

* These provider types were added in 2021.

Reporting entities:

  • Applicable manufacturers
  • Applicable Group Purchasing Organizations (GPOs)

What is being reported and when?

Annually by March 31, Cook must submit a detailed report to CMS of payments or transfers of value made the prior calendar year. The financial reports include:

  • The physician’s name
  • The dollar amount of the payment or transfer of value
  • The nature of the payment (chosen from a pre-determined list of categories—see the next question for more information)
  • A brief contextual description of why the payment was needed

Review and dispute period: After CMS combines all the reported data, registered physicians and teaching hospitals are given 45 days to review the data for accuracy and resolve disputes with the manufacturers. A template dispute form is available to physicians and teaching hospitals registered with CMS to view the data. Manufacturers then have 15 days to correct and resubmit the data.

Each year by June 30: CMS publicly posts the data from the previous calendar year.

What is a transfer of value?

Providing anything with discernible economic value, tangible or intangible, directly or indirectly. Below are examples of what is considered a transfer of value under Open Payments. These are called “nature of payment” in the CMS database and are considered a transfer of value.

  • Acquisitions
  • Charitable contributions
  • Compensation for non-consulting services (e.g., faculty/speaker at event other than a continuing education program)
  • Compensation for serving as faculty or as a speaker for a medical education program
  • Consulting fees (fee-for-service work)
  • Current or prospective ownership or investment interest
  • Debt forgiveness
  • Education
  • Entertainment
  • Food and beverage
  • Gifts
  • Grants
  • Honoraria
  • Long-term medical supply or device loan
  • Research activities, including enrolling patients in clinical trials
  • Royalty or license
  • Space rental or facility fees
  • Travel and lodging

These nature of payment categories were added in 2021.

Can I find out what's being reported from Cook Medical under my name?

Yes. You have two options.

  1. Physicians and teaching hospitals may request a report directly from Cook Medical at or by calling 1.800.457.4500.
  2. Physicians and teaching hospitals can view the data on the CMS website during the review period. They need to register to access the database.

Will physicians and teaching hospitals need to report transfers of value?

No, physicians and teaching hospitals do not need to collect or submit to CMS data about transfers of value they have received. They may want to keep track of payments received from manufacturers so that they can verify that the correct information was reported, however.

Note that some transfers of value to physicians in a group, such as at a group dinner, are averaged across the number of attendees. The reported average dollar amount is not specific to what each person ordered from a menu.

Expenses are recorded at the time payment is issued to the physician or teaching hospital, not the time the expense was incurred.

Are any transfers of value exempt from reporting?

Yes. Here is a partial list of exempt payments or transfers of value:

  • Payments or other transfers of value less than:
    • $12.69 (up to $126.89 total per physician) for 2023
    • $13.07 (up to $130.66 total per physician) for 2024
  • Items under a certain value provided at large-scale conferences or events, where it would be difficult to establish the identities of the recipients of the item:
    • Less than $12.69 for 2023
    • Less than $13.07 for 2024
  • Educational materials that directly benefit patients or are intended for patient use. This does not include educational materials provided to physicians for their own education.
  • Discounts and rebates.
  • In-kind items for the provision of charity care.
  • Product samples, which are defined as demonstration and evaluation products that are intended for patient use.
  • Short-term (less than 90 days) loans of equipment.

Please visit the CMS Open Payments website for more information.

Can I reimburse the company for a transfer of value after the fact?

No, CMS has decided that reimbursement is not allowed after a transfer of value has occurred. However, at events that qualify as reportable transfers of value, we are able to offer physicians the option of paying for their own expenses before the expense is incurred. If they register for this option at the time of the event, physicians are sent invoices after the event to pay within 30 days.

What if I disagree with a transaction that has been reported to CMS?

Before each annual posting of data, physicians will be given 45 days to review the data and resolve disputes directly with manufacturers. Manufacturers then have 15 days to correct and resubmit the data.

Physicians and teaching hospitals will need to register with CMS to access the database and to dispute data that has been reported. The CMS website provides a dispute template.

Where can I get more information about Open Payments?

The CMS and AMA websites both have more detailed information about Open Payments.

In addition, we at Cook Medical have a team who can help with questions from physicians and teaching hospitals. Please feel free to send us an email at or call us at 1.800.457.4500 with your specific questions.