CMS Open Payments Rules and Database

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Now Available - 2023 Open Payments Physician and Teaching Hospital Resources

The CMS Open Payments team, in consultation with the AAMC’s FOCI Steering Committee and AAMC staff, have developed educational resources for use at your institution. In anticipation of the upcoming release of the 2022 Open Payments data in June 2023, these resources are designed to help educate physicians about the Open Payments program and for authorized representatives of teaching hospitals.

Open Payments Pre-publication Review and Dispute Available April 1-May 15, 2023

Physician and teaching hospitals have from April 1 - May 15, 2023, to review and dispute payment records for Program Year 2022. Physician and teaching hospital review of the data is voluntary but encouraged to ensure records are accurate before publication on the Open Payments website in June 2023.

Important reminders:

Disputes must be initiated by May 15, 2023, to be reflected in the June 2023 data publication.
CMS is not responsible for the facilitation of disputes. Physicians and teaching hospitals should communicate directly with reporting entities for resolution.
Program Year 2022 data is inclusive of physicians, teaching hospitals, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists & anesthesiologist assistants, and certified nurse-midwives.
Registration in the CMS Identity Management System is required to participate in review and dispute. If you have already registered, you can go directly to the CMS Portal to participate in the review and dispute process. For more information about the registration process, visit the covered recipient registration page on the Open Payments website.

Background

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 annually report to CMS 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.

Physicians and teaching hospitals have the opportunity to review and dispute the payments reported about them before the data are made publicly available on the CMS Open Payments website on or by June 30. In order to participate in the review and dispute process, registration in the Open Payments system is required (register here).

CMS Resources

Covered Recipient Registration for Physician & Non-Physician Practitioners
Covered Recipient Registration for Teaching Hospitals
Open Payments Overview Video (2022)
Natures of Payment Video (2022)
Provides high level details about the different payments reported in the Open Payments system.
Open Payments Program Year 2019 Data
Open Payments Registration for Teaching Hospitals and Physicians (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 publicly reported data. For Questions, contact the Open Payments Help Desk (1-855-326-8366)
Resources for Covered Recipient (Registration, User Roles, Nominations, Review & Dispute)
Open Payments User Guide for Covered Recipients - February 2021
CY 2015 Physician Fee Schedule Proposed Rule (CMS proposed making four changes to the Sunshine Rule for calendar year 2015. See pages 40383-40385 for the Open Payments Program).
Comment Request - Activities Relating to the Revision of Registration, Attestation, Dispute & Resolution Assumptions Document and Data Retention Requirements for Open Payments (May 2014)
Federal Register Notice of the Final Rule, Transparency Reports and Reporting of Physician Ownership or Investment Interests (February 2013)
Federal Register Notice of the Proposed Rule, Transparency Reports and Reporting of Physician Ownership or Investment Interests (December 2012)

AAMC Resources

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