Review, dispute or correct 2017 data before May 15 deadline.

Is your data correct? Time to review Open Payments data

Once again, the Centers for Medicare & Medicaid Services (CMS) offer doctors a window to review and dispute their Open Payments data before that information is published online.

"Physicians and teaching hospitals are able to initiate disputes through the Open Payments system during the review and dispute period."

Given that manufacturers self-report Open Payments data, it's important for doctors to look over and potentially dispute any inaccurate payment data before the review window closes May 15, 2018. Afterward, CMS will publish this 2017 Open Payments data online, June 30, 2018.

Each year, the Open Payments program collects information about the payments that physicians and teaching hospitals receive from drug and device companies, and group-purchasing organizations, for travel, research, gifts, speaking fees, meals or other natures of payment. This data is then made available to the public via a searchable database online.

Publicly reported payments received by doctors include:

  • Cash or cash equivalent
  • In-kind items or services
  • Stocks, stock options, or any other ownership interest, dividend, profit or other return on investment
  • Any other form of payment or other transfer of value

"Physicians and teaching hospitals are able to initiate disputes through the Open Payments system during the review and dispute period, which follows the data submission period each program year," CMS notes. "Applicable manufacturers and GPOs are able to review disputed records and take action to correct the records and resolve any issues directly with physicians and teaching hospitals. Any discussion pertaining to the resolution of a disputed record must take place outside of the Open Payments system between the applicable manufacturer or GPO and the disputing physician or teaching hospital."

How to review, dispute data

To review data, doctors must be registered in CMS' Enterprise Identity Management and Open Payments systems, and doctors also may nominate a staff member to review. Once registered, log in to review your data. CMS also posts notices on its Open Payments webpage and sends notifications via its listserv when data is ready for review.

  • If you haven't accessed your account in 60 days or more, unlock your account in the CMS Portal.
  • If you haven't accessed your account in 180 days or more, your account has been deactivated and will need to be reinstated by contacting the Open Payments Help Desk at or 855.326.8366.

Doctors may review and dispute Open Payments data at any time; however, during this review period, doctors can review data prior to the June 30 publication. Following the March 15 deadline, drug and device companies have an additional 15 days to fix any disputed records.

Keep in mind that data may only be disputed in the year it is first published-e.g., 2017 data, published on June 30, 2018, may only be disputed until Dec. 31, 2018-so it's important to review Open Payments data annually.

Click here for more information about the Sunshine Act.

April 19, 2018

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