Conflict of Interest

News and Updates

Physician Payment Sunshine Act

Important Update:

The Open Payments 45-day review and dispute process began on April 1 and is currently underway. The review process is voluntary but in order to review and correct the data, physicians will need to register in both the CMS Enterprise Identity Management System (EIDM) and the Open Payments system. You do not need to go through the registration process again if you registered previously. This is the third reporting year, and it covers payments made in 2015. The updated database will become public on June 30, 2016.

Open Payments is a national disclosure program that publishes financial relationships between the medical industry and physicians on a publicly accessible web site. Information includes payment for such things as consulting, speaking, honoraria, gifts, travel, lodging and research support.

Under the ruling, the term “physician” applies to doctors of

  • Medicine
  • Dentistry
  • Dental Surgery
  • Optometry
  • Chiropractic Medicine
  • Podiatry
  • Osteopathy

Physicians may review and dispute any data reported about them, provided they are registered with CMS.

To register with CMS, visit the CMS Portal.


After physicians register on the CMS Portal and in Open Payments, they may delegate an authorized representative who can review and dispute on their behalf. The delegate will also have to go through the CMS Portal and Open Payments registration process. Once the delegate has registered, they will need to accept the nomination as the physician's delegate.

Tips for Physicians

In preparing to review the data in Open Payments, physicians should:

  • Keep accurate records of payments made from industry for such things as consulting fees, travel, etc.
  • Make sure the disclosure with The University of Iowa is current (go to the eCOI system to view or update your disclosure)
  • Register on the CMS Portal to create a profile
  • Register on the Open Payments System and review information (if any) submitted by industry; dispute if necessary

Please note there may be inconsistencies between the CMS database and the UI Health Care disclosure database, due to different reporting timelines and payment categorization differences. Only individuals (the physician him/herself or his/her delegate) can view and dispute reported payments.

For additional information, visit the CMS Open Payments Program or the CMS Open Payments Program Frequently Asked Questions. The AAMC has also posted an "Open Payments Overview for Physicians" document.

If you have a question about the federal regulation on conflict of interest in research, please call the Conflict of Interest in Research Office at 384-4256.

Faculty and staff at University of Iowa Health Care have increasing opportunities to engage in professional activities with industry and other outside entities.

Such activities may improve patient care through the development of new products; strengthen knowledge and skills; and contribute to the growth and development of expertise. Yet care must be taken to ensure that relationships between UI Health Care employees and outside entities are free from any actual or perceived conflicts of interest.

To reinforce our commitment to upholding the highest possible ethical standards and to foster greater transparency, University of Iowa Health Care implemented a Conflict of Interest/Conflict of Commitment policy on July 1, 2009. A revised version of the policy is effective on April 29, 2016.

A summary of changes lists the major changes to the revised policy.

Disclosures of external relationships made by UI Health Care faculty and staff members are publicly accessible.

If you have questions about the policy, please contact the Conflict of Interest Office at 319-384-5252 or