The Centers for Medicare and Medicaid Services (CMS) has released a guide for physicians to prepare for the Dispute Resolution period of the Physician Payments Sunshine Act. Currently, announced for "mid-July" for when physicians and teaching hospitals can begin registration in the Open Payments system.
Registration in Open Payments is voluntary for physicians and teaching hospitals, but it is required if the physician or teaching hospital wants to access the data so that they can review and dispute what has been reported about them by manufacturers. CMS split registration for physicians and teaching hospitals into two phases for this first Open Payments reporting year:
Phase 1 (available at any time): Includes user registration in CMS' Enterprise Portal. Enterprise Portal registration is a required first step to allow for registration in the Open Payments system when it becomes available in mid-July. Use the Phase 1 Step-by-Step CMS Enterprise Portal Registration for Physicians and Teaching Hospitals presentation for guidance on how to complete this portion of the registration; this resource is also posted on the Physicians and Teaching Hospitals pages of the Open Payments website.
Phase 2 (begins in mid-July): Allows physicians and teaching hospitals to:
- Register in the Open Payments system,
- Delegate roles and responsibilities by nominating system users to fill specific user roles, and
- Review and dispute data submitted by applicable manufacturers and applicable GPOs prior to public posting of the data. Note, however, that any data that is disputed, if not corrected by industry, will still be made public but will be marked as disputed.
While there is no official end date for when physicians and teaching hospitals must finish the registration steps, if the physician or teaching representative wants to participate in the review and dispute period for 2013 Open Payments data, CMS advises that registration in EIDM and Open Payments is completed by the end of the initial 45-day review/dispute period. CMS states that "identity verification for registration will take some time, so CMS recommends completing the registration process as soon as possible and not waiting until close to the end of the initial 45-day period."
How to Prepare for Phase 2 Come Mid-July
- Have your CMS Enterprise Portal user ID and password readily available (reminder, this was created in Phase 1);
- Think about nominating individuals to interact with the Open Payments system on your behalf (such as, a physician or teaching hospital authorized representative/official);
- Gather any records of payments, transfers of value, ownership or investments that you may have received between August 1, 2013 and December 31, 2013;
- Ask your local industry representative if any organization they represent has reported to CMS any data on payments, transfers of value you have received, ownership or investment interests you have held; if so, ask for a copy;
- Organize your industry contact information as you will be working directly with them to resolve any disputes or answer any questions you may have in regards to the data they've reported.
CMS is developing a number of educational resources to support physicians and teaching hospitals with this next step of Open Payments system registration. CMS will "soon announce step-by-step guides to registration in the Open Payments system and other supporting resources."
On July 22, CMS will host a National Provider Call. In the coming weeks, the registration link for the call will be posted to the Event page of the Open Payments website at http://go.cms.gov/openpayments