December 14, 2020 - Physician and teaching hospitals have until December 31, 2020 to review and dispute publicly available payment records for program year 2019. Registration is required to review the publicly available data on the Open Payments website. If you are already registered, you can go directly to the CMS Portal to participate in the review and dispute process. To register, visit the Registration Information Page.
June 4, 2020 - Physician and Teaching Hospital Resources. The CMS Open Payments team in consultation with the AAMC's Forum on Conflict of Interest Steering Committee, and AAMC staff, developed two educational resources for use at your institutions: one with information to educate physicians about the Open Payments program and another for authorized representatives of teaching hospitals. (Physician Educational Slides PDF) (Teaching Hospital Educational Slides PDF)
March 30, 2020 - Review and Dispute for Physicians and Teaching Hospitals Begins April 1 until May 15, 2020.
Reports about payments from industry to physicians and teaching hospitals are made publicly available through the CMS Open Payments website. We encourage you to review records of payments you have received in 2019 before the end of the review and dispute period. In order to complete the review and dispute process, you must register in the Open Payments system (register here). Registration must be completed to perform any Open Payments functions before publication of the data on or by June 30, 2020.
September 27, 2019
- On July 29, 2019, CMS released the 2020 Proposed Medicare Physician Fee Schedule Rule, which included several important changes, including updates to the Open Payments Program (Section III. F). These changes are intended "to limit burden in the Open Payments program reporting processes and improve clarity for the public." Specific changes to Open Payments include: Expanded definition of "covered recipient, modification of the Nature of Payment categories, and standardizing data on reported covered drugs, devices, biologicals, or medical supplies."
The AAMC submitted comments to CMS on September 27, 2019. Read the AAMC's response to the proposed rule (comments on the Open Payments program begin on page 15).
March 13, 2019 - Open Payments National Provider Call. CMS
hosted an Open Payments national provider call (Transparency and You) to provide information on the April 2019 review, dispute, and correction process for physicians and teaching hospitals, as well as information on how to register in the Open Payments system. (Presentation) (Transcript)
April 2018 - CMS' Annual Report to Congress on the Open Payments program (here)
Opportunity to Provide Feedback to AAMC on the Open Payments Program
The AAMC is currently working to identify ways in which the Open Payments program and website could be enhanced or modified, and will share these suggestions with CMS. Please click here to provide your feedback.
Teaching hospitals and physicians must be registered in the Open Payments system to participate in the review and dispute process (*registration is a two step process- step 1: register in the Enterprise Identity Management System & step 2: register in the CMS Portal. Step 2 is required to see the reported data)
- Methodology and Data Dictionary (January 2019)
- Open Payments Program Overview and Enhancements (January 2019)
- Open Payments Program Data Publication Tutorial (June 2018)
- Summary of Open Payments Data (Program Years 2013-2017)
The CMS rule, "Transparency Reports and Reporting of Physician Ownership or Investment Interests" also known as the Physician Payments Sunshine Act, requires applicable manufacturers of drugs, devices, biologicals, or medical supplies to report to CMS on an annual basis certain payments or transfers of value made to physicians or teaching hospitals. It also requires manufacturers and group purchasing organizations to disclose physician ownership or investment interests. The data are published annually. Physicians and teaching hospitals have the opportunity to review and dispute the payments reported about them before the data are made publicly available.
- Proposed Changes to the Rule - In the CY 2015 Physician Fee Schedule proposed rule, the Centers for Medicare and Medicaid Services (CMS) proposed making four changes to the Sunshine rule for calendar year 2015.
- Federal Register Notice of the Proposed Rule (July 11, 2014) - see pages 40383-40385
- AAMC Urges CMS to Retain Sunshine Act Exemption for Accredited CME (Sept. 2014)
- AAMC Letter to CMS Regarding Delays in the Open Payments Review and Dispute Process (Aug. 2014)
- AAMC Comment Letter in Response to the Proposed Dispute Resolution Process (June 2014)
- Federal Register Notice of the Final Rule (Feb. 2013)
- AAMC Comment Letter in Response to NPRM (Feb. 2012)