Open Payments Applicable Manufacturers & Applicable GPOs: Program Year 2016 Review, Dispute, and Correction April 12, 2017 CMS Disclaimer: This information is a summary of the Final Rule implementing Open Payments (Medicare, Medicaid, Children's Health Insurance Programs; Transparency Reports and Reporting of Physician Ownership or Investment Interests [CMS-5060-F], codified at 42 CFR Parts 402 and 403). The summary is not intended to take the place of the Final Rule which is the official source for information on the program.
Program Year 2016 Timeline 2016 PROGRAM YEAR April 1 – May 15, 2017 January 1 – February 1 – June 30, 2017 December 31, 2016 March 31, 2017* May 16 – May 30, 2017 2
Open Payments System: Review and Dispute Enhancements • Updated Columns on Review and Dispute grid for reporting entities • To reduce scrolling, the following columns have been removed from the grid: • File ID • Date of Payment • Dispute Last Modified By • Records Status 3
Review, Dispute, and Correction Reminders • Review and Dispute began on April 1, 2017 and continues through May 15, 2017 • In order for the dispute or correction to be reflected in the June 30, 2017 data publication, the dispute must be initiated by May 15, 2017 • Extended correction period continues from May 16, 2017 – May 30, 2017 • Dispute resolution takes place outside of the Open Payments system • Reporting entities should work directly with the physician, physician’s authorized representative, physician principal investigator, or a teaching hospital’s authorized official or authorized representative to reach a resolution for the dispute • CMS does not mediate disputes between reporting entities, physicians and teaching hospitals 4
Review, Dispute, and Correction Actions Permitted Actions by Reporting Entities Permitted Actions by Physicians and Teaching Hospitals Acknowledge disputes Review and Affirm records • • Resolve disputes with changes to records Initiate disputes • • Resolve disputes by deleting records Withdraw disputes • • Resolve disputes with no changes to records • • It is not required that physicians and teaching hospitals review, acknowledge or dispute any records • Records not affirmed by the physician and teaching hospitals are eligible for publication and will be published using the latest attested – to date submitted by the reporting entity • Only users who hold the role of submitter can perform review, dispute, and correction actions for the reporting entity • Changes made to records are not complete until the record is re-attested by a user who holds the role of attester 5
Status of Disputes Status Definition Initiated The dispute has been initiated by a physician or teaching hospital Acknowledged The dispute has been acknowledged by the reporting entity Resolved The dispute has been resolved by the reporting entity with updates made to the record Resolved No Change The reporting entity and physician or teaching hospital have resolved the dispute in accordance with the Final Rule and no change were made to the disputed record Withdrawn The dispute has been withdrawn by the physician or teaching hospital 6
Review and Dispute Published as Published as Disputed in Disputed on June Refresh Dispute Initiated Dispute Resolved 30? Publication? By the end of the 15-Day Correction No No Period During the 45-day Review and Dispute Yes, unless the After the End of Period dispute is resolved the 15-Day Yes before the end of Correction Period the calendar year 7
Review and Dispute Published as Published as Disputed in Disputed on June Refresh Dispute Initiated Dispute Resolved 30? Publication? By the end of the 15-day correction No No period During the 15-day Yes, unless the correction period After the end of dispute is resolved the 15-day No before the end of correction period the calendar year 8
Review and Dispute Published as Published as Disputed in Disputed on June Refresh Publication? Dispute Initiated Dispute Resolved 30? By the end of the No No calendar year After the correction period After the end of No Yes the calendar year Information available in Open Payments Methodology Overview & Data Dictionary https://www.cms.gov/OpenPayments/Downloads/OP-datadictionary.pdf 9
Question and Answer Session • If you would like to ask a question via the phone line please use the ‘raise hand’ feature and the moderator will call on you and unmute your line. • You may also submit questions via the Q&A Chat Box • Please note all specific scenario questions should be directed to the help desk. • Please limit phone line questions to one question 10
Available Resources • Review available resources on the Resources page of the CMS Open Payments website at https://www.cms.gov/OpenPayments/About/Resources.html • Open Payments User Guide – Tutorials – Quick Reference Guides – Register for CMS email notifications via the Open Payments website to receive e-mail updates about Open Payments • Open Payments Help Desk: – openpayments@cms.hhs.gov – 1-855-326-8366 11
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