December 4, 2013

Open Payments Program Update

Open Payments Program Update

As part of our ongoing effort to keep you informed of the latest developments related to the OPEN PAYMENTS Program (Physician Payments Sunshine Act), the following new resources are now available on the CMS website:

Additional OPEN PAYMENTS FAQs Added
These new FAQs are related to a wide variety of Open PAYMENTS topics, including loans for covered devices, clarification on when a distributor is considered an applicable manufacturer and how to classify a number of different forms of payments.

Notice in Federal Register: Public Comments for CMS-10495
In accordance with the Paperwork Reduction Act (PRA), OPEN PAYMENTS published a notice in the Federal Register requesting public comments for CMS-10495 (Registration, Attestation, Dispute and Resolution, Assumptions Document and Data Retention Requirements for OPEN PAYMENTS). This PRA package explains the OPEN PAYMENTS registration data to be collected from applicable manufacturers and applicable GPOs, plus the data needed from physicians and investors for them to register for the program and review the data provided by applicable manufacturers and applicable GPOs. The 60-day public comment period on CMS-10495 closes on September 20, 2013.

Two Continuing Medical Education Activities are Available
Also available for physicians to learn more about OPEN PAYMENTS is a continuing medical education (CME) activity. Two such activities are available and accessible via Medscape; both are accredited by the Accreditation Council for Continuing Medical Education (due to email formatting restrictions, please review the version of this document on the Open Door Forum page for details of the two activities.)

Medscape accounts are free and users do not have to be health care professionals to register. Registration can be found on the Medscape website

Data Submission File Specifications (formerly known as Data Collection Templates)
The OPEN PAYMENTS program website includes the data submission file specifications for 2013; physicians, applicable manufacturers and applicable GPOs should become familiar with the categories used to describe reportable payments or other transfers of value, and ownership or investment interests. These specifications are critical, as they will be needed for data submission in early 2014. The OMB control number is 0938-1173.

Note, the first OPEN PAYMENTS program cycle (August 1, 2013 through December 31, 2013) is a partial data collection period of only five months, as compared to future program cycles which will run for the entire year. For this first period, the data collected by applicable manufacturers and GPOs through December 31st, 2013 will be submitted to CMS in early 2014. Physicians do not need take any action or submit data to CMS. They will have the opportunity to review the submitted data and work with the applicable manufacturer and applicable GPO to correct their submitted information before CMS makes it public.

CMS Created Mobile Apps to Assist with Payment Tracking As physicians, applicable manufacturers and applicable GPOs begin tracking financial data, remember that there are new mobile apps available to assist in OPEN PAYMENTS implementation, one for industry use and one that physicians may use. Indeed, the objective for these apps is to make tracking payment information easier and more convenient, and to improve the accuracy of payment information by tracking payments as they occur throughout the year.

You can download the mobile apps directly from your app store (iOS Apple™ or GooglePlay™); search for either OPEN PAYMENTS Mobile for Industry or OPEN PAYMENTS MOBILE FOR PHYSICIANS. The upcoming National Provider Call on August 8th will provide a demonstration of the apps’ functionality; to register, visit MLN Connects Upcoming Calls.

For any questions relating to OPEN PAYMENTS, contact the Help Desk at [email protected].

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