Getting Ready for Open Payments

Today, the Centers for Medicare and Medicaid Services (“CMS”) released additional tips regarding submitting Open Payments data.[1]

A quick refresher: Submitting data through CMS’s application, Open Payments, is the means to fulfill the Sunshine Act, a federal regulatory requirement that applicable manufacturers, group purchasing organizations (“GPOs”), and health care providers disclose: a) certain transfers of value given to physicians and teaching hospitals, as well as b) any ownership or investment interest physicians, or their immediate family members, may have in their company.

As previous Open Payments reporting entities know all too well, submitting data in the Open Payments system requires careful attention to detail, and can often be a time-consuming, painstaking process. CMS’s notice included a new document, “Open Payments Submissions Suggestions,” highlighting, among other things, two key issues for reporting entities to be aware of heading into this year’s submission period:

  • Accuracy is important. While users may submit data in the appropriate field and format, if the content of the submission contains errors – even minor errors such as stray punctuation – the content of the submission will not be valid.
    • Takeaway for reporting entities: Carefully reviewing and validating submissions, and ensuring enough time during the process to do so, is key to a smooth and stress-free Open Payments submission process. Note that even extra spaces at the tail end of a field will cause your submission to error out – one must scrutinize that closely.
  • Submit early in the reporting period. While reporting entities have until March 31, 2019 to report data, CMS reminded users that the system becomes busy towards the end of the reporting period – we have, in fact, seen the system hang as the submission deadline nears. Should reporting entities uncover problems, they may find themselves scrambling to meet the reporting deadline.
    • Takeaway for reporting entities: Allotting enough time to review and validate data well in advance of the March 31, 2019 deadline ensures that any uncovered issues can be addressed without becoming major obstacles to meeting the reporting deadline. We recommend that you complete your data formatting and input no later than six weeks prior to the deadline (roughly mid-Feb.) to allow time for initial submission, clean-up of errors, and correction of those errors for final submission.

We hope this notice was helpful, and we are happy to answer further questions.  Dorsey Health Strategies has extensive experience in preparing and submitting Open Payments submissions on behalf of our clients, and we’d be pleased to help your organization with this year’s submission. If you’d like to learn more about how we can support you, please contact us at 612.492.6418.

[1] Note that the Open Payments submission window is fast approaching, opening on February 1, 2019.

Kristen Barlow

Kristen is a consultant with the Dorsey health strategies team. Kristen works with clients to solve a variety of strategic, operational, and compliance challenges. She has worked particularly with hospitals, clinicians, and post-acute care providers, including but not limited to selecting clinical episodes for bundles, understanding payment reform regulations, improving post-acute efficiency, narrowing post-acute networks, and working with managed care payers.

Shira Hauschen

Shira is Managing Principal of Dorsey Health Strategies. Shira has advised clients across a wide array of industry segments on topics including compliance with federal and state laws, healthcare IT, Big Data, telemedicine and mobile health, lean transformations (process improvement), vendor management, and integrated delivery systems. As a licensed attorney and via the integrated approach taken by Dorsey’s Health Care Industry Group, Shira’s consulting advice is attuned to and aligned with clients’ legal landscape.

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