Life Science Compliance Update

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October 28, 2013

Physician Payment Sunshine Act: CMS Updates Teaching Hospital List for 2014 and No Changes to File Specifications

As required in the final rule for 2014 Open Payments data collection (from January 1, 2014 through December 31, 2014), the 2014 Teaching Hospital List was released on October 1 by the Centers for Medicare & Medicaid Services (CMS). Here is the link to the Open Payments "Teaching Hospital" page.

CMS noted that this list should only be used for 2014 data collection and should not be used for any other program year.

The format of the 2014 Teaching Hospital List has been enhanced since the release of the 2013 Teaching Hospital List.

On the 2014 list, CMS is now including an entity's common business name in addition to its legal business name. This change has been made in response to inquiries from institutions governed by a single body that were not listed separately in the 2013 list.

The data should be submitted separately for each common business name and TIN combination appearing on the list. This will help to make the data more easily understood by users, as well as easier to collect for applicable manufacturers and applicable Group Purchasing Organizations (GPOs), who will no longer have to determine whether a hospital is owned or operated by a legal entity on the teaching hospital list.

Other Updates for the 2014 Program Year

  • 2014 Submission File Specifications: For 2014, there are no changes to the  submission file specifications .
  • Key Reporting Thresholds: In accordance with §403.904 (h)(2)(i)(2)(ii), the Open Payments reporting thresholds specified in §403.904 (h)(2)(i)(2)(i) have been adjusted based on the consumer price index.
  • This means that for 2014 (January 1 through December 31), if a payment or other transfer of value is less than $10.18 ($10.00 for 2013), unless the aggregate amount transferred to, requested by, or designated on behalf of a covered recipient exceeds $101.75 in a calendar year ($100.00 for 2013), it is excluded from the reporting requirements under Open Payments.

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