"Do you want to review Open Payments data reported about you before it is available to the public?"
That's the question CMS recently posed when it announced physicians could begin registering(www.cms.gov) in the agency's Open Payments system to review and, if necessary, dispute data detailing payments or other transfers of value they received from drug and device manufacturers before those data become publicly available later this year.
Under the Physician Payments Sunshine Act -- a provision of the Patient Protection and Affordable Care Act -- pharmaceutical and medical device manufacturers are required to report payments or other transfers of value, including ownership and investment interests, to physicians and teaching hospitals. Thanks, in large part, to the efforts of the AAFP(2 page PDF) and other stakeholder groups, CMS has created a process through which physicians may dispute inaccurate data reported about them to the agency's Open Payments transparency program.
To participate in the review process, physicians must be registered in both the CMS Enterprise Portal(portal.cms.gov) and the Open Payments system on or before Aug. 27. Registration in the agency's Enterprise Portal provides a layer of security for physicians who plan to register in the Open Payments system and must be completed first.
According to a detailed timeline CMS has developed for the rollout of its Open Payments program, physicians have from now through Aug. 27 to register in the Open Payments system and review and dispute any data submitted by industry with which they disagree before the data are published online on Sept. 30.
The current reporting period covers data about transfers of value submitted from Aug. 1 through Dec. 31, 2013. Subsequent reporting cycles will include data collected throughout the entire 12-month calendar year.
Because identity verification is part of the registration process and requires some time, CMS recommends that physicians complete the registration process as soon as possible and not wait until the end of the initial review period.
Manufacturers will evaluate disputed data and work with physicians to make necessary corrections. Data pertaining to any dispute that is initiated but not resolved before the Aug. 27 cutoff will still be made public on Sept. 30, but will be marked as disputed.
Manufacturers may continue the corrections process, including resubmitting and re-attesting to revised data reports to CMS, through Sept. 11; data updates made during this 15-day period may be reflected in the Sept. 30 public release.
Additional details about the Sunshine Act and the Open Payments program timeline are available on the AAFP Open Payments page.
Still have questions? Then sign up for a call aimed at health care professionals, medical staff, professional organizations and other stakeholders that is scheduled for July 22 from 2:30-4 p.m. EDT. During the call, CMS experts will provide an overview of the registration, review and dispute processes. Those interested in participating need to register(www.eventsvc.com) beforehand for the call.
CMS Open Payments User Guide(www.cms.gov)