The Centers for Medicare and Medicaid Services today made a number of announcements related to their Open Payments system, mostly aimed at correcting mismatched physician payments that were withheld or de-identified in the initial data release.
CMS Returns Payment Records for Review and Correction
Starting today, manufacturers have the opportunity to review and correct 2013 payment records returned from the intermingled data fix that went into effect in August. To get started, log-in to the Open Payments system to download a "Removed Records Report" which will show which records across all three payment types (general, research, and ownership/investment interests) were removed from the published identified data, and why each individual record was removed.
After reviewing this report, you can re-submit corrected records to the Open Payments system. Step-by-step instructions on this process, and a detailed explanation of the reasons for record removal, are included in the Quick Reference Guide: Applicable Manufacturer and GPO Removed Records Report. CMS notes that once the records are re-submitted and re-attested (at a later date), physicians and teaching hospitals will then be able to review and dispute that information, and the information can be publicly posted.
Reporting entities will be required to submit corrected records into the Open Payments system no later than the end of the 2014 data submission and attestation period—March 30, 2015—and be published in the data release projected for June 30, 2015.
CMS is also hosting a webinar for applicable manufacturers and group purchasing organizations with a returned record report on Thursday, November 13, 2014; 1:00 p.m. – 3:00 p.m. EST.
- Registration link: https://event.webcasts.com/starthere.jsp?ei=1047138; to register, enter your name and email address into the box titled “Complete this form to enter the webinar.”
- Dial-in information: Please use the link you receive after you register for the session to access the online portion of the webinar, and use this phone bridge line to listen to the audio portion:
- Meeting Number: 996 876 705 (a password is not required)
Data Matching Support Resource: Validated Physician List
We noted earlier this year that a source of the problems with Open Payments had to do with how physician information was matched from what companies provided on the one hand to CMS's own data on the other. Today, CMS stated: “[m]any of the inconsistencies identified in the returned records are a result of physician identifiers not exactly matching against CMS or external data sources.” They state that to “proactively assist with data matching, and in an effort to be fully transparent about the method and data sources used to validate submitted data, CMS is publishing a downloadable list of physician data in CSV format, which contains variations of physician first/last name, NPI and state license number, for physicians who were reported in the Open Payments system.”
This Validated Physician List is accessible in the Open Payments system via the CMS Enterprise Portal. CMS encourages applicable manufacturers and GPOs to utilize the provided physician list to avoid further inconsistencies in data reporting.
Each individual record in the Removed Record Report includes a “Reason for Deletion.” If the reason for deletion is because the physician data you originally provided did not match what is contained within CMS sources, simply update your submitted data to match what is shown in the Validated Physician List. If you cannot find the physician on the Validated Physician List, review the information in the National Plan & Provider Enumeration System (NPPES)(https://nppes.cms.hhs.gov/NPPES/NPIRegistryHome.do).
Last Chance: Correct Disputed 2013 Data by Friday, October 31
Finally, CMS states that manufacturers and GPOs have until Friday, October 31 to make data corrections to any 2013 Open Payments disputed records for publication in the data refresh on or before December 31, 2014. "Please note that these disputes were initiated by physicians and teaching hospitals during the review and dispute period held earlier this year," states CMS.