What is Open Payments?

Open Payments is a federally run transparency program that will increase public awareness of financial relationships between the health care industry and physicians by collecting and making public any payments or transfers of value between drug and device manufacturers and physicians or teaching hospitals. The Centers for Medicare & Medicaid Services (CMS) will require the collection of information from manufacturers of drugs and devices about payments or other transfers of value they make to physicians and teaching hospitals. These payments can be for many purposes, such as research, consulting, travel, and gifts. CMS will collect this data annually, and make this data publicly available and searchable on a website each year.

Why is this program important?

Open Payments will create transparency into the financial relationships physicians and teaching hospitals have with drug and medical device manufacturers. These transactions happen each year for many reasons. This program doesn’t make assumptions or draw conclusions about the information reported. CMS will simply make the program available to the public to create transparency and allow interested stakeholders to analyze, monitor, and use the data. It also provides a platform for physicians, teaching hospitals, and other groups to ensure that information reported about them is accurate. It’s important that you, as the physician, know about this
program, what’s reported about you, and how you can answer questions from your patients.

Outline

• Open Payments System Overview
• Open Payments System Enhancements
• Next Steps and Available Resources

Covered Recipient Teaching Hospitals

•The hospitals that CMS has recorded as receiving payment(s) under Medicare Direct Graduate Medical Education (GME), indirect medical education (IME), or
psychiatric hospitals IME programs
•Each year, Open Payments publishes a list of these teaching hospitals; the list is available on the Resources page of the Open Payments website at https://www.cms.gov/OpenPa yments/About/Resources.html

• The AM/GPO Officer(s), Compliance User(s), and the Primary Point of Contact users can view and download file types, such as excel, CSV etc.
• The AM/GPOs will receive only one generic email notification when multiple communications are finalized by the CMS Compliance user.
• The AM/GPOs will also be able to see all the past correspondence compliance communications uploaded by the CMS Open Payments compliance team

• The system is enhanced to avoid entities being stuck in an “Unknown Error” status after registration and/or updating entity profile.
• If the “Unknown Error” status is triggered in the Open Payments system, the Home page will display the status as “Vetting in Progress”
• If the vetting status remains in Vetting in Progress for 48 hours, users should contact Help Desk to resolve the issue.

Which physicians and teaching hospitals are affected?

The physicians affected by the program include:
• Doctors of medicine and osteopathy
• Dental surgeons
• Dentists
• Licensed chiropractors
• Optometrists
• Podiatrists

Note: You’ll still be affected even if you don’t treat Medicare or Medicaid patients. Also, medical residents are excluded from the definition of physicians for the
purpose of this program.
The teaching hospitals include institutions that received payments for:
• Indirect medical education (IME)
• Direct graduate medical education
• Psychiatric hospital IME
CMS will publish a list each year identifying the teaching hospitals that are affected.

What kinds of payments will be reported?
Drug and medical device manufacturers must report most payments made to physicians and teaching hospitals. Examples include:
• Consulting fees
• Speaker fees
• Honoraria
• Gifts, like promotional gadgets, items useful in a medical practice, or vacations
• Entertainment, like tickets to a sporting event, concert, or theater show
• Food and beverage
• Travel and lodging
• Education, like textbooks and medical refresher courses
• Research activities, including enrolling patients in clinical trials
• Charitable contributions
• Royalties or licenses
• Current or prospective ownership or investment interest
• Grants, for example, to support education, operations, or meetings

Is there anything I need to do?

In order to review data that will be made public, resolve disputes, and make corrections, you should register with the Open Payments system at go.cms.gov/openpayments.
The system will be available in early 2014. We also encourage you to:
• Become familiar with the program and the information that will be reported about you.
• Keep track of your financial interactions with the health care industry. A free mobile app is available to help you track the payments you receive. See below for more information.
• Sign up at go.cms.gov/openpayments to get email updates about the Open Payments program, including events and educational opportunities.
• Work with companies to make sure the information submitted about you is correct.
• Review the information companies may submit on your behalf prior to public posting.
• Learn what to do if you disagree with the information that’s submitted. When the review period starts in 2014, you’ll be allowed to dispute information that you don’t think is accurate or complete.
What resources are available to help me track required Open Payments reporting?
A free app (Open Payments Mobile for Physicians) is available to help you track the payments you get from the health care industry so you can compare them with the
information reported about you. The app:
• Can be downloaded at the Google Play™ app store or iOS Apple™ app store. Search for Open Payments Mobile for Physicians.
• Gives you a simple, easy-to-use tool to track transfers of value in real time on your own phone.
• Can also be used to share profile and transfer-of-value information between physician and industry apps.
• Is for personal information collection and serves as a storage depository only.
It doesn’t interact with CMS systems, CMS contractors, and can’t be used directly for data reporting to CMS or its contractors.
Note: CMS won’t check the accuracy of data stored in the app, and it isn’t responsible for protecting data stored in the app. You have the sole responsibility for the
accuracy and completeness of the data submitted to CMS about you by the health care industry under Open Payments. For help with the app, email OpenPayments@cms.hhs.gov.

Where can I get more information?
• Visit go.cms.gov/openpayments to get more information about the Open Payments program and mobile app.
• Visit www.medscape.com for a continuing medical education activity that’s accredited by the Accreditation Council for Continuing Medical Education.


You’ll learn more about the steps involved in collecting and reporting physician data, key dates for implementation, and actions you can take to verify your information.

Open Payments (Physician Payments Sunshine Act)

Why Open Payments is Important to You

Open Payments requires:
• Applicable manufacturers of covered drugs, devices, biologicals, and medical supplies must report payments or other transfers of value they make to physicians and teaching hospitals to CMS.
• Applicable manufacturers and applicable group purchasing organizations (GPOs) to report to CMS certain ownership or investment interests held by physicians or their immediate family members.
• Applicable GPOs to report to CMS payments or other transfers of value made to physician owners or investors if they held ownership or an investment interest at any point during the reporting year. CMS will collect the data annually, aggregate it, and publish it on a public website.


Open Payments
• Speaks to public concerns about physician and industry relationships by collecting and reporting data.
• Helps to make financial relationships among industry, physicians, and teaching hospitals clear.
• Provides one place for financial interactions to be reported and monitored.
• Sets requirements so that it is easier for physicians and other stakeholder groups to make sure the information reported about them is accurate.
• Stop dishonest influence on research, education, and clinical decision-making.
• Stop conflicts of interest that can harm patients and their care.

The Intent of Open Payments

We view this program as a national resource for beneficiaries, consumers, and providers to know more about the relationships among physicians, teaching hospitals, and industry.

How Open Payments Works

Applicable manufacturers and applicable GPOs (“Reporting Entities”) will tell us every year about:

  1. Payments and other transfers of value from applicable manufacturers of covered drugs, devices, biologicals, or medical supplies to physicians and teaching hospitals (“Covered Recipients”).
  2. Payments and other transfers of value from applicable GPOs to physician owners/ investors.
  3. Ownerships or investments held by physicians or their immediate family in applicable manufacturers and applicable GPOs.

Physicians’ Voluntary Participation

Physicians are not required to register with or send any information to the Open Payments. However, to make sure we have the right information, we do encourage physicians to:
• Become familiar with the information that will be reported about physicians.

Introduction

Open Payments, which is managed by the Centers for Medicare & Medicaid Services (CMS), is a national disclosure program created by the Affordable Care Act (ACA). The program promotes transparency and accountability by helping consumers understand the financial relationships between pharmaceutical and medical device industries, and physicians and teaching hospitals. These financial relationships may include consulting fees, research grants, travel reimbursements, and payments made from the industry to medical practitioners.

It is important to note that financial ties between the health care industry and health care providers do not necessarily indicate an improper relationship.

This document provides a guide to how CMS publishes the informational data gathered by Open Payments for public use. It explains the sources of the data, the data files that are available from CMS, and the fields contained in each data file. View the data and learn more about the Open Payments program by visiting