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May 12, 2014

Physician Payments Sunshine Act: Physician and Teaching Hospital Registration Requirements, Lack of Dispute Resolution in New Documents

The Office of Management and Budget (OMB) posted documents that provide a lot of insight into the next steps of the Open Payments system for the Physician Payments Sunshine Act that pertain to physicians. The Centers for Medicare and Medicaid (CMS) have not yet released detailed information on the Submission and Attestation process, but the OMB Information Collection Request sheds light on important aspects of Phase 2 including the physician and teaching hospital registration which is now rescheduled to begin June 1, 2014.

Notably, we saw that physicians may now be required to provide their DEA number in addition to the NPI, and State License number, and License State, as seen in the full list of registration requirements below. According to CMS from a recent Webinar, physicians will register through the EIDM registration system (enterprise portal) which requires home address and social security number in addition to the Open Payments information listed on the chart below. Physicians direct billing Medicare should already be in the EIDM system and require the additional Open Payments information.

PHYSICIAN REGISTRATION

PHYSICIAN IDENTIFIERS

1. CMS USER ID: System generated CMS User ID assigned by EIDM; required for registration in Open Payments
2. Name: Full legal name (first, middle, last, suffix). Provide the legal name as listed in the National Plan & Provider Enumeration System (NPPES).
3. NPI (National Provider Identifier): Individual NPI for a single physician (and not the NPI of a group of physicians).
4. License # and License State: A valid, official state license # and the state of the physician; provide the "License State and License Number" pairs, if a physician is licensed in multiple states.
5. DEA Number: A valid U.S. Drug Enforcement Administration (DEA) number assigned to a health care provider for tracking of prescribed controlled substances.
6. Primary Type of Medicine practiced by the physician (covered recipient). For the purposes of Open Payments, covered recipient physicians may be any of the following: Medical Doctor (MD), Doctor of Osteopathy (DO), Doctor of Dentistry (DDS), Doctor of Podiatric Medicine (DPM), Doctor of Optometry (OD), and Chiropractor (DCP).
7. Specialty Code: The physician specialty code of the physician (covered recipient) as listed in the health care provider taxonomy codes list.
8. Email: The primary business email address for the physician, who has received a payment or transfer of value. Provide the preferred email for communications from Open Payments about the program and information reported by applicable manufacturers and applicable group purchasing organizations.

PHYSICIAN PRACTICE IDENTIFIERS

1. Registering Physician Practice Name: The legal name of the practice or group practice (a single legal entity with two or more physicians legally organized as a partnership, professional corporation, foundation, not-for-profit-corporation, faculty practice plan, or similar association). Physicians have the option to enter additional practice names.
2. Physician Practice Business Address: The primary business (or practice location) address (Number and Street (or PO Box), City, State, and 9-digit Zip Code) of the physician, who has received payments or transfers of value. For international addresses, also provide the Province, Country and International Postal Code, if applicable. Physicians have the option to enter addition practice business addresses.
3. Registering Physician Practice Phone Number: The primary business phone number for the physician who has received a payment or transfer of value. Provide the preferred phone number for communications from Open Payments about the program and information reported by applicable manufacturers and applicable group purchasing organizations about the covered recipient.

PHYSICIAN AUTHORIZED REPRESENTATIVE IDENTIFIERS

 

1. Authorized Representative Name: Legal name (first, middle, last, suffix) of an individual authorized by the physician (covered recipient) to access/review data and initiate a dispute on behalf of the physician.
2. Authorized Representative Job Title: Official title of the position held by individual authorized by the physician to access and review physician's data or initiate a dispute in Open Payments.
3. Authorized Representative Email: The primary business email address for the individual or employee of the physician practice authorized by the physician to access/review data and initiate a dispute on behalf of the physician in Open Payments.
4. Authorized Representative Phone Number: Primary business phone number for individual or employee of the physician practice authorized to access/review data and initiate dispute on behalf of the physician.
5. Authorized Representative Business Address: Primary business address for the individual or employee of the physician practice authorized to access/review data and initiate a dispute on behalf of the physician.

________

What we also found interesting was a comparison between the documents currently posted on CMS.gov (see Supporting Statement) with the OMB documents (in the Supporting Statement Part A), related to Dispute Resolutions.

In both Supporting Statements, CMS states:

"This PRA package is to inform the public about information collected that is necessary for registration, attestation, dispute resolution and corrections, record retention, and submitting an assumptions document within Open Payments."

However, the new OMB document is completely missing Part 3. Dispute Resolutions and Corrections (CMS document on the top, OMB on the bottom):

The missing section may be caused by the recent call for comment from CMS and OMB on the dispute resolution process.

Furthermore, the dispute resolution process seems to have been wiped off of the hours of burden chart (CMS documents above, OMB below):

OMB:

CMS has been slow to announce much information related to Dispute Resolution, but it will be interesting to see why they removed the process from its documents. We will keep you informed with more updates regarding the Physician Payments Sunshine Act.

Call for Comments:

Physicians and teaching hospitals will be able to register in the CMS system starting June 1st. However, they will not be able to access the system or dispute the data until a yet unannounced date in July, August or September.

Recently we wrote that the Centers for Medicare and Medicaid Services (CMS) posted a notice for interested parties to submit comments on the Dispute Resolution period of Open Payments (Physician Payment Sunshine Act) in the Federal Register,.

In its call for comment, CMS states:

"[W]e are announcing the addition of the dispute resolution and corrections process to this information collection request (ICR). The dispute resolution and corrections process was discussed in our initial submission to OMB. However, based on the detailed processes of review and corrections as well as the sensitivities around these processes, we felt it appropriate to solicit additional public feedback on how these interactions would occur. Therefore we are resubmitting a revised ICR for OMB review and approval. While we are submitting a revision of the entire ICR, we are specifically seeking comments on the dispute resolution and comment process" (emphasis added).

Comments are due by June 2, 2014, giving physicians one day from the time they register (June 1) to assess the system and formulate comments. 

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