Last week, CMS opened applicable manufacturer registration for phase I for Open Payments, the CMS program to administer the Physician Payments Sunshine Act. We provided analysis of the Open Payments Phase I Registration and Submissions here.
CMS has posted a number of new resources to the Open Payments website to educate stakeholders about the two-phased approach to Open Payments registration and data submission. Finally, CMS has posted more Frequently Asked Questions on its website. You can find our previous coverage of the Open Payments Frequently Asked Questions here.
Additional Phase 1 Registration and Data Submission Resources Now Available
CMS has posted a number of new resources to the Open Payments website, in an effort to educate our stakeholders about the two-phased approach to Open Payments registration and data submission that began on February 18. Read more below about the newly available resources:
New frequently asked questions (FAQs) added to the CMS FAQ website to address some of the most common questions about the phased approach to Open Payments registration and data submission (including user role details and an explanation of how consolidated reports are not accepted in Phase 1). At the end of this article we have included the CMS Q&A in full text format.
No action is needed from affected physicians and teaching hospitals at this time. CMS will soon issue more specific information regarding the dates for Phase 2 registration and data submission, as well as when registration and review/correction will open for covered recipients, which will be no later than August 1, 2014.
Reminder: Phase 1 Instructions
Step 1: New User Registration with CMS Enterprise Portal (EIDM Registration)
The first step of Phase 1 requires industry to register in the CMS Enterprise Portal athttps://portal.cms.gov. For detailed instructions on completing Phase 1 registration, visit theProgram Registration page on the Open Payments website. Now posted to this page is apresentation of step-by-step screenshots to walk a user through the registration process.
The authorized official (an entity's executive-level officer who can legally represent their organization) must register in the CMS Enterprise Portal and obtain their CMS user ID. The CMS user ID is required for any future data submissions in the Open Payments system. CMS registration must be completed before industry can begin any 2013 data submission activities, so we advise entities to begin the registration process soon to allow ample time for the authentication process, which can take up to 10 days in some rare cases. Note: The authorized official can then manually delegate data submission responsibilities to others (referred to as authorized representatives) after CMS Enterprise Portal registration. This manual delegation is done through the sharing of the authorized official's CMS user ID directly with another trusted person in their entity, who can then use that to complete data submission on the authorized official's behalf. CMS is not involved in the distribution or sharing of CMS user ID's for this purpose of delegation, and this exchange is performed outside of CMS systems.
Step 2: Aggregate Data Submission
After CMS Enterprise Portal registration has been completed, the user will be directed to a webpage that will explain the requirements for Phase 1 data submission. The authorized official (or an authorized representative) should download the data submission instruction document and the sample template available on this page. The instruction document is not available on the Open Payments website but available here, and is accessible after CMS registration is completed. The sample template is now posted to the Open Payments website (on the Data Submission and Attestation page) to provide general information on the data submission requirements; however, please note that the instruction document is still required for proper understanding and completion of the template.
- After registration has been completed, the authorized official or authorized representatives must submit the corporate profile information and aggregate 2013 payment data to CMS as instructed on the webpage and in the data submission instruction document. As explained in the instruction document, the CMS user ID must be noted in the subject line of the email sent to CMS containing the aggregate data.
- When Phase 1 data has been submitted as instructed, the Open Payments Help Desk will reply directly to the submitter, confirming if the submitted data meets all requirements. If information is missing or improperly formatted, CMS will provide additional instructions on how to correct the data submission.
Coming Next – Phase 2 Instructions
After Phase 1 registration and data submission, CMS will utilize your submitted data from Phase 1 to create your entity profile and prepare for Phase 2 data submission.
When Phase 2 of registration and data submission begins (in approximately May 2014), the authorized official in the officer role will need to complete the following actions:
- Using their CMS user ID from Phase 1, complete Open Payments registration for the entity and the authorized official by providing additional information within the Open Payments system,
- Confirm the accuracy of the entity profile data that was submitted in Phase 1 and pre-populated in the Open Payments system for Phase 2, and
- Upload or enter, submit, and attest to the accuracy of the detailed 2013 payment data.
In addition, in Phase 2 the authorized official will also be able to delegate actions and roles to others at their entity, so they can also use the Open Payments system to upload or enter, submit, and attest to the 2013 data.
For the 2013 program year, CMS will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission. The review and correction phases will begin by August 1; additional information regarding the review and correction processes will be announced in spring 2014.
This phased approach to Open Payments registration and data submission is for the 2013 program year only (data collected between August 1, 2013 and December 31, 2013).
For more information about Open Payments, please visit the Open Payments website. To sign up for the Open Payments listserv, access the website at http://go.cms.gov/openpayments, and enter your email address on the main page, in the "Email Updates" box, or on the "Contact Us" page. Submit any questions to the Help Desk at: firstname.lastname@example.org.
Email Address to Submit March 31st Aggregate Report OPdata@cms.hhs.gov
New Open Payment Questions from CMS
Consolidated reporting is only applicable in Phase 2. In Phase 1, consolidated reports will not be accepted. Individual entities need to submit their aggregate data individually.
The authorized official is an entity's executive-level officer who can legally represent their entity and manage the entity's profile within the Open Payments system and therefore begin the chain of trust among the other individuals interacting with the system. Activities specific to the authorized official's role is limited to registering the entity, but authorized officials may also perform other activities as an officer such as approving user role requests made by others, delegating roles to others, as well as submitting and attesting to data.
The officer role is initially delegated to individuals within the entity by the authorized official. Once approved in this role, no functional differences exist between the authorized official role and the officer role. An officer may approve other authorized representatives on behalf of the authorized official, manage the entity in the Open Payments system, and delegate roles to others. An officer can also be delegated as a "submitter" or "attester," and can then submit or attest to the validity of data.
This is an optional field, but providing your social security number can facilitate identity verification.
What if the automated identity verification function does not work for me? (FAQ9726) 2-24-2014
A manual work-around will be available, but please be aware that this manual process could take up to two weeks, so early registration is advisable.
Select "Open Payments User".
I do not see the yellow "Open Payments" button on the portal. Where is it?
You must first request access to Open Payments in order for the yellow button labeled "Open Payments" to appear on the Enterprise Portal homepage. To do this:
- Log back in to the CMS Enterprise Portal by clicking "Login to CMS Secure Portal", accept the Terms and Conditions, and enter your user ID and password
- Once logged in, click "Request Access Now" on the right hand side of the CMS Enterprise Portal home page
- Request access to the Open Payments system by clicking on "Request New Application Access" on the left hand side of the page
- Select "Open Payments" from the drop down menu
- A second drop down will then appear prompting you to select an Open Payments role in the system
- Select "Open Payments User" and then click "Submit"
- You will then see the "Identity Verification" page, click on "Next"
- You will then see the "Terms and Conditions" page, select the check box next to "I agree to the terms and conditions" and click "Next"
- Fill out the requested fields on the "Your Information" page and click "Next"
- On the "Verify Identity" page select the correct answer for each question to verify your identify and when completed click "Next"
- On the "Complete Step Up" page click "Next"
- You will then see an acknowledgement message, click on "OK"
- Then log out of the system by clicking "Log Out" in the upper right hand corner of the page
- Log in to the CMS Enterprise Portal once again by clicking "Login to CMS Secure Portal" and entering your user ID and password
- On the CMS Enterprise Portal home page you should now see a yellow button labeled "Open Payments" next to "My Portal" on the upper left hand side of the page
- When you click on "Open Payments" you should have an option labeled "Registration" appear beneath it
- Click on "Registration" to access details about the first step of Phase 1 of detailed data submission, CMS Enterprise Portal (EIDM Registration)
- You will now see the Open Payments Registration Page