Recently the data on payments and transfers from physicians became public. Now there is a way for physicians and teaching hospitals to dispute that information if they believe it to be inaccurate or incomplete. Although registration will open on the  on June 1, 2014, registration by a physician is voluntary to make sure CMS has the right information. Teaching hospitals are encouraged to:

  • .
  • Keep records of all payments and other transfers of value received from applicable manufacturers and applicable group purchasing organizations (GPOs). While CMS has not yet developed specific resources for teaching hospitals to track transfers of value, staff of teaching hospitals can use the  app to track payments and other transfers of value they receive from applicable manufacturers and applicable GPOs throughout the year.
  •  and .

Registration for physicians and teaching hospitals will be conducted in two phases for this first Open Payments reporting year:

  • Phase 1 (begins June 1) includes user registration in CMS’ Enterprise Portal.
  • Phase 2 (begins in July) includes physician and teaching hospital registration in the Open Payments system and allows them to review and dispute data submitted by applicable manufacturers and GPOs prior to public posting of the data. Note: Any data that is disputed, if not corrected by industry, will still be made public but will be marked as disputed. 
    • CMS is committed to data accuracy, and will be closely monitoring this process to ensure integrity in the data posted. We encourage teaching hospital engagement in this process. Teaching hospitals that notice an inaccuracy can dispute data and work with applicable manufacturers and GPOs to resolve disputes.
    • Applicable manufacturers and GPOs may be audited based on activities that pertain to their compliance with Open Payments requirements to submit timely, accurate, and complete data. Audits and civil monetary penalties do not apply to teaching hospitals as a result of any reported activities.

In the coming weeks, CMS will provide additional guidance about how to complete the CMS registration process, and when Phase 2 registration and the review and dispute process will begin for physicians and teaching hospitals.

Teaching Hospital Listing

For the 2013 Open Payments program cycle, click on the link below to access a listing of all teaching hospitals to be reported on: []. For the 2014 Open Payment program cycle, click here: []

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Studiomaca Business Performance Services offers services and consulting to help hospitals, health systems, and physician practices improve business performance, boost margins and transition successfully to value-based care.