4 steps to prepare now for Open Payments data

4 steps to prepare now for Open Payments data

AOA members have access to a new resource that outlines immediate steps to comply with the "Sunshine Act," otherwise known as the Open Payments program.

To assist members with this process, the AOA's Federal Relations Committee has developed guidance that outlines steps for program registration and also explains how the Open Payments program operates.

Authorized by the Affordable Care Act, the program intends "to shed light on relationships between health care providers and makers of medical devices, drugs, biologicals, and devices" covered by public health care programs, the guidance explains.

The program mandates that certain manufacturers and others report any payments or gifts provided to ODs and other physicians. Such items may include consulting fees, honorarium, gifts, food and beverage, lodging and travel, and education.

The committee's guidance also emphasizes that the Open Payments program does not prohibit such activities—it only requires disclosure of the activities. Reporting is not a responsibility of the health care providers; it is required only of certain manufacturers and group purchasing organizations (GPOs). 
 
A website created by the Centers for Medicare and Medicaid Services (CMS) will make this data publicly available on September 30.

What ODs need to do now
To prepare for open payments this summer, the AOA's guidance provides a "to do" list for ODs:

  1. Register on the CMS Enterprise Portal (EIDM). Registration opened June 4. CMS will conduct a soft credit and identity check, but it won't affect your credit rating.

  2. Starting in July, register in the Open Payments system, accessible through the EIDM. Passwords will need to be changed every 60 days.

  3. Review data reported by manufacturers and GPOs for accuracy through the Open Payments system. You will have only 45 days to review and, if necessary, correct any data.

  4. If data is incorrect, you may contact the manufacturer through the Open Payments system to dispute the posted data. Once a dispute is received, the manufacturer can correct the data or leave it as posted. 

"The only recourse to change data that the manufacturer will not correct the first time is to submit another dispute," the guidance states.

If you have problems with disputed data, inform the AOA's Washington, D.C., office. Email Kara Webb, a regulatory policy and quality assessment specialist for the AOA.

July 10, 2014

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