Sunshine Act overview
Note: This article is primarily for Admins, Controllers, and Compliance teams managing healthcare-related spend.
Overview
Available on Ramp Plus. See Ramp Plus overview for plan details.
Ramp’s Sunshine Act functionality helps healthcare and life sciences companies track, manage, and report payments to healthcare providers (HCPs) in compliance with federal Open Payments regulations. These features are built into Ramp, reducing manual work and eliminating the need for external tools.
What is the Sunshine Act?
The Sunshine Act is a federal law requiring certain companies in the healthcare industry to disclose payments and other transfers of value made to physicians and teaching hospitals. These reports are submitted annually to the Centers for Medicare & Medicaid Services (CMS) and published via the Open Payments system.
If your business manufactures, markets, or distributes drugs, devices, or medical supplies reimbursed by federal healthcare programs, you’re likely required to comply.
How Ramp helps
Ramp makes it easier to meet your Sunshine Act obligations by integrating data collection directly into expense workflows.
Key features include:
- HCP tagging at the point of spend (web and mobile)
- Auto-suggest for recent HCPs to streamline entry
- Custom fields for National Provider Identifier (NPI), nature of payment, and related product
- Ramp Reporting dashboards for monitoring year-to-date spend
- CMS-ready CSV export
Reporting workflow
- Swipe card for Sunshine-related expenses in Ramp as they occur (on web or mobile)
- Search for and add HCPs using their NPI numbers, first name and last name, or a combination of name plus the two-letter state code (using a custom field or dropdown.
- Complete three required Sunshine-related coding fields :
- Form of payment: the default is cash or cash equivalent
- Nature of payment: 17 Open Payments categories
- Related products: select up to five
- Review transactions in Ramp Reporting to ensure completeness
- Export the CMS-compatible CSV file at the end of the calendar year
- Alternatively, export a raw CSV file for auditing or sharing with third-party partners based on a specific date range.
- Upload to CMS Open Payments Portal between January and March
Ramp helps teams avoid manual consolidation by embedding compliance directly into your existing workflows.
Supported features
| Feature | Status |
|---|---|
| Sunshine Act signing in the expense flow | Supported |
| Federal-level Sunshine Act report generation (Open Payments format) | Supported |
| Exportable CMS-compatible CSV files | Supported |
| Exportable Raw CSV file for preferred time range | Supported |
| Insights dashboard and downloadable reporting | Supported |
| Mobile data entry and tracking | Supported for iOS (Version 121) and Android (Version 0.100.2) |
| Recently used HCPs (auto-suggest) | Supported |
Limitations
Ramp’s Sunshine Act compliance features are designed to streamline reporting for companies subject to federal Open Payments rules. However, some advanced or edge-case needs are out of scope for this release.
Not supported
- State-level reporting requirements.
- Direct submission to CMS : Ramp generates the file, and customers must upload it manually with their own credentials.
- Organizational ID collection : Ramp does not auto-populate Company, Manufacturer, or GPO IDs.
- Dispute or resubmission management: All reports are treated as first-time exports.
- Bulk HCP uploads or deduplication
- Uneven splits for multiple HCPs on a single transaction
- Related product tagging in UI: Can only be managed through internal tools, not via Ramp’s main UI.
- In-app management of HCP data: Admins cannot yet manage synced vs manually added HCPs directly in Ramp.
Tip: Ramp is a data collection and export tool. Your compliance team should handle final validation and regulatory filing.
Reportable spend categories
Ramp allows tagging and tracking for the most common Open Payments categories, including:
- Meals and beverages
- Travel and lodging
- Speaking or consulting fees
- Royalties and license payments
- Research-related payments
- Charitable contributions
- Ownership or investment interest
- Entertainment and gifts
We recommend confirming with your legal or compliance team which categories apply to your expenses.
Getting access
Sunshine Act reporting is available to all Ramp customers on theRamp Plusplan.
To enable this feature, visit the Integrations tab and search for Ramp Sunshine Act Compliance.
From the same screen, Admins can:
- Add and manage their list of related products
- Update CMS export file configuration fields
- Disable Sunshine Act at any time (with no loss of existing data)
Frequently asked questions
Does Ramp submit my file to CMS?
No. Ramp generates the required file with correct formatting, but customers must upload it directly to the Open Payments portal.
Can I use Ramp if I already track this manually in Excel?
Yes. Ramp helps automate the process and produces a clean, CMS-ready export. No spreadsheet wrangling required.
Does this work with my ERP?
Yes, Ramp’s Sunshine Act features work with all ERP integrations. You can tag Sunshine fields like HCP, form of payment, and related products in Ramp, regardless of your ERP. These details stay in Ramp for reporting, while the expense itself syncs to your ERP as usual.