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Physician Financial Transparency Reporting (Sunshine Act) 

Open Payments is Section 6002 of the Patient Protection and Affordable Care Act (Public Law No. 111-148), as amended by the Health Care and Education Reconciliation Act of 2010 (Public Law No. 111-152).

The Physician Payments Sunshine Act is designed to increase transparency around the financial relationships between physicians, teaching hospitals and manufacturers of drugs, medical devices and biologics. The Centers for Medicare & Medicaid Services (CMS) fulfills the law’s mandate via the Open Payments Program. CMS collects information from GPOs and applicable manufacturers and reports information about their financial relationships with physicians and hospitals. The Sunshine Act does not ban any relationships or collaboration. (Source: Open Payments website, https://www.cms.gov/OpenPayments, last visited 01/13/2020).

Pharmaceutical and medical device manufacturers, including AngioDynamics, Inc., must submit annual data on payments and transfers of value made to covered recipients. Physicians have 45 days to review their Open Payments data and dispute errors before public release. If the deadline is not met, physicians can still review and dispute errors, and corrections will appear in the database’s next scheduled update.

Please note that AngioDynamics is required to track expenses for all healthcare professionals (HCPs). Expenses for different HCP types are reportable under different rules and regulations. For Sunshine Act purposes, payments and expenses for doctors (MD, DO, DDS/DMD, DPM, OD, DC) are reportable. Payment categories include:

  • General Payments: payments or other transfers of value not made in connection with a research agreement or research protocol.
  • Research Payments: payments or other transfers of value made in connection with a research agreement or research protocol.
  • Physician Ownership Information: information about physicians who have an ownership or investment interest in an applicable manufacturer or applicable GPO.
  • Transfer of value of capital equipment on loan to a physician or teaching hospital: after the first ninety (90) days of an equipment evaluation period, AngioDynamics is required to report a transfer of value for such equipment under Open Payments.
  • Medical residents are excluded from the definition of physicians under the Sunshine Act, but fellows are included. (Source: Open Payments website, http://www.cms.gov/OpenPayments/Explore-the-Data/Data-Overview.html, last visited 01/13/2020).

The expanded definition of a covered recipient, as outlined in the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act), will be effective for data collected beginning in calendar year 2021 (and reportable to CMS in 2022). The SUPPORT Act expands Open Payment’s definition of a covered recipient to include five additional HCP types:

  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Certified nurse midwives


Teaching hospitals are also covered recipients and include institutions that receive payments/transfers of value for:

  • Medicare direct graduate medical education (GME)
  • Inpatient prospective payment system (IPPS)
  • Indirect medical education (IME)
  • Direct graduate medical education
  • Psychiatric hospital IME
  • Transfers of value of capital equipment on loan to a teaching hospital: after the first ninety (90) days of an equipment evaluation period, AngioDynamics is required to report a transfer of value for such equipment under Open Payments.

Should you have questions about the Sunshine Act and Open Payments, please visit cms.gov/OpenPayments. Should you have questions on AngioDynamics’ Sunshine Act reporting policies and procedures, please email compliance@angiodynamics.com.

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