Life Science Compliance Update

April 11, 2017

Open Payments Starts Review and Dispute…On A Saturday

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With the close of Open Payments submission just behind us, the Centers for Medicare & Medicaid Services (CMS) plans to publish the Open Payments Program Year 2016 data and updates to the 2013, 2014, and 2015 program years on June 30, 2017.

As such, the review and dispute period for the Program Year 2016 Open Payments data publication begins on Saturday, April 1, 2017 and will last until Monday, May 15, 2017. Physicians and teaching hospitals must initiate their disputes during this 45-day review period in order for any disputes to be addressed before the June 30th publication.

Physician and teaching hospital review of the data is voluntary, but strongly encouraged by CMS. While the opportunity for physicians and teaching hospitals to dispute any data associated with them expires at the end of the calendar year in which the record is published, the disputes must be addressed during the 45-day review and dispute period, ending on May 15th, in order to be reflected in the June 30th publication. 

To those who have never registered in the Open Payments system before, you will need to create an account. To do so, make sure you have your National Provider Identifier (NPI) number, Drug Enforcement Agency (DEA) number, and State License Number (SLN). Initial registration is a two-step process and should take approximately 30 minutes: first, you will need to register in the CMS Enterprise Identity Management System (EIDM) and from there, you can register in the Open Payments system.

Physicians and teaching hospitals who registered last year do not need to reregister in the EIDM or the Open Payments system. If the account has been accessed within the last 60 days, go to the CMS Enterprise Portal, log in using your user ID and password, and navigate to the Open Payments system home page.

However, the EIDM locks accounts if there is no activity for 60 days or more. To unlock an account, go to the CMS Enterprise Portal, enter your user ID and correctly answer all challenge questions; you’ll then be prompted to enter a new password. The EIDM also deactivates accounts if there is no activity for 180 days or more. To reinstate an account that has been deactivated, contact the Open Payments Help Desk.

CMS Is Offering a Teleconference on the Review and Dispute Process

Join the Centers for Medicare & Medicaid Services (CMS) on April 13, 2017 for an informative session on the Open Payments Review and Dispute process.

This National Provider Call will provide physicians and teaching hospitals an opportunity to learn about the review and dispute process, including how to access the Open Payments system to review the accuracy of the data submitted before it is published on the CMS website.

A question and answer session will follow the presentation. Topics covered will include: overview of the Open Payments Program; Program Timeline; Registration Process; and critical deadlines for physicians and teaching hospitals. 

March 31, 2017

Access Problems Persist with Open Payments…

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With less than two days left to submit and attest to data for the June 30, 2017, publication, manufacturers and group purchasing organizations (GPOs) continued to have problems with the CMS Open Payments Portal. (Today is the deadline – we received notice that the site was down late Wednesday night).

Seen below is a screenshot we were sent from one of our sources, which notes that the “CMS Enterprise Portal is currently not available due to an outage. We apologize for any inconvenience. Please try back later.”

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CMS has sent several “reminder” emails this week about the upcoming deadline, but nothing about the consistent problems we have heard from several sources. CMS helpfully reminds applicable manufacturers and applicable GPOs that they can “complete the data submission and attestation activities by logging into the Open Payments system through the EIDM Portal, but leaves off any information for help other than “Contact the Help Desk.”

Our question to CMS is, how do they expect companies to fully comply with these onerous requirements when they cannot even get the site up and running well enough for manufacturers and GPOs to input their information in the most efficient way possible?

March 28, 2017

Whatever the Question, Transparency Isn’t the Answer

Transparency

Many in political (and non-political) circles have blamed a lack of pricing transparency for increasing healthcare costs. However, as recognized in a study published in The Journal of the American Medical Association, improving transparency is not the answer. More than half of the states in the United States have passed laws that either establish websites with health care prices or require plans, doctors, and hospitals to disclose them to patients. Some employers and other organizations even provide health care prices to employees and the public.

However, according to the study, such transparency doesn’t always help patients spend less. The AMA article investigated the effect of transparency of the Truven Treatment Cost Calculator, a website that is available to more than twenty-one million workers and their family members. The website provides users with the costs (both the total price and the portion the user would be responsible for) from over three hundred services, including various sorts of imaging, outpatient operations and physician visits.

The researchers compared outpatient health care spending of 150,000 employees who had access to the website with that of about 300,000 comparable employees who did not. However, despite its features, the cost calculator wasn’t popular. Even though sixty percent of employees with access to it had a deductible of at least $500, only ten percent used it in the first year of availability and twenty percent after two years of availability. The study found that price transparency did not reduce outpatient spending, even among patients with higher deductibles or those who faced higher health care costs because of illness.

This Study is Not an Outlier

Many other studies show the same thing. Health plans report that use of their price transparency tools is limited, with many enrollees entirely unaware that they even exist. The majority of plans now provide pricing information to enrollees, but roughly two percent actually look at it. Aetna, for example, offers a price transparency tool to 94 percent of its commercial market enrollees, but only 3.5 percent of the enrollees use it.   

A study of New Hampshire residents found that only one percent used the state’s health care price comparison website over a three-year period. Another study found that the use of the price transparency platform Castlight Health was associated with lower payment for lab tests, advanced imaging and office visits; however, the study did not examine outpatient spending overall.

Why Is This?

Dennis Scanlon, a Penn State health economist, is not surprised by this result. “Health care choices are different than most product and services. Most decisions are driven by physician referrals, and insured patients usually face little variation in costs across options”

Another possible reason that people don’t cost-shop for health care is that they find the process to be too complex. As we have said time and time again, providing more information to consumers doesn’t always improve their decision making, in fact, many times, it can overwhelm a consumer and lead to poorer choices. It is easier to go somewhere based on a recommendation, even if it costs more.

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