Frequently Asked Questions

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Are dental schools that are affiliated with universities and health care institutions, but do not match the name or address information provided on CMS’ teaching hospital list, still considered teaching hospitals for the purposes of reporting?

The teaching hospital list compiled by CMS is a complete list of teaching hospital covered recipients. Applicable manufacturers and applicable group purchasing organizations should collect the TIN from a hospital, or in this case, dental school, that they believe is affiliated with a teaching hospital in order to correctly identify the teaching hospital’s name and address from the list. Additionally, as discussed in the proposed and final rule, a teaching hospital is any institution that received payments under sections 1886(d)(5)(B), 1886(h) or 1886(s) of the Act.

Key words: Open Payments, Sunshine Act

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