On April 1, the review and dispute for the June 30, 2016 Open Payments data publication began and will last for 45 days. CMS is required to collect information about financial relationships between the health care industry, physicians, and teaching hospitals. Open Payments
is the federally run program that collects the information about these financial relationships and makes it available to the public. When physicians register in the Open Payments system, they are able to review the data reported about them (before the public can).
According to CMS, they will publish the 2015 payment data and updates to the 2013 and 2014 data on June 30, 2016. In order for any disputes to be addressed before the June 30th publication, physicians and teaching hospitals must initiate their disputes during the 45-day review period, and industry must resolve the dispute before the publication deadline. Review and dispute is voluntary, but strongly encouraged. The opportunity for physicians and teaching hospitals to review and dispute the data submitted about them expires at the end of the year that the record is published.
The CMS announcement states:
Drug and device makers are currently submitting data to the Open Payments System on payments or transfers of value made to physicians and teaching hospitals during 2015. When data submission ends, physicians and teaching hospitals will have 45 days to review and dispute records attributed to them in order for those disputes to be resolved before the data is published on June 30, 2016. In order to review the data, physicians and teaching hospitals need to register in the Open Payments system
. Physicians and teaching hospitals can register at any time. Additional instructions from CMS on registration are below.
If You Have Never Registered In Open Payments Before:
•Before you begin, make sure you have your National Provider Identifier (NPI) number, Drug Enforcement Agency (DEA) number, and State license number (SLN). Initial registration is a two-step process and should only take 30 minutes:
1. Register in the CMS Enterprise Identity Management System (EIDM);
2. Register in the Open Payments system
For Users That Registered Last Year and Have Used Their Accounts in the Last 60 Days:
•Physicians and teaching hospitals who registered last year do not need to reregister in the EIDM or the Open Payments system. If the account has been accessed within the last 60 days, go to the CMS Enterprise Portal, log in using your user ID and password, and navigate to the Open Payments system home page.
For Users That Registered Last Year but Have Been Inactive for More than 60 Days:
•The EIDM locks accounts if there is no activity for 60 days or more. To unlock an account, go to the CMS Enterprise Portal, enter your user ID and correctly answer all challenge questions; you’ll then be prompted to enter a new password.
For Users That Registered Last Year but Have Been Inactive for More than 180 Days:
•The EIDM deactivates accounts if there is no activity for 180 days or more. To reinstate an account that has been deactivated, contact the Open Payments Help Desk.
Information on CMS Open Payments Program
CMS Q and A