Have You Checked Your CMS Open Payments Record Recently?

Each year, CMS makes information publicly available regarding the amount of payments that drug and device companies made to physicians in the prior year. This is published under the Open Payments program, which is a federal program required by the Affordable Care Act. The Open Payments program collects data pertaining to payments that drug and device manufacturers made to physicians and teaching hospitals, as well as any ownership interests that the physician or his/her immediate family members may have in such companies. Reportable payments include travel, research, gifts, speaking fees and meals received by physicians.

CMS publishes a particular year’s payment record by June 30th of the following year (i.e., payments in 2016 will be published on June 30, 2017). Starting in April of each year, a physician will have 45 days to review his/her personal data prior to the June 30th publication of the preceding year’s data.

Physicians should annually check their Open Payments record to ensure that the amounts reported are accurate. Incorrect data can be disputed, but physicians only have until the end of the calendar year in which the date is published to review and report any disputed information. As an example, a 2015 record that CMS publishes on June 30, 2016 can only be disputed until December 31, 2016. Any changes made to the data as a result of the dispute will be publicly available in January of the following year.

Further information about reviewing and disputing incorrect data in the Open Payments system can be found here: https://www.cms.gov/OpenPayments/Program-Participants/Physicians-and-Teaching-Hospitals/Review-and-Dispute.html. The best practice is to annually review your Open Payments data. As is often told to patients, an ounce of prevention is worth a pound of cure.