National Physician Payment Transparency Program
On Feb. 8, 2013, the Centers for Medicare & Medicaid Services (CMS) published a final rule titled the “Medicare, Medicaid, Children's Health Insurance Programs; Transparency Reports and Reporting of Physician Ownership or Investment Interests.” The intent is to increase transparency in the financial relationships in the health care marketplace. The “National Physician Payment Transparency Program: OPEN PAYMENTS,” rule is part of the Affordable Care Act legislation.
As part of this program, applicable manufacturers and applicable GPOs will begin tracking and reporting payments and other transfers of value made to physicians and teaching hospitals, as well as certain ownership interests held in the organizations by physicians and their immediate family members. CMS will collect the data annually, aggregate it, and publish it on a public website.
In order to give applicable manufacturers and applicable GPOs sufficient time to prepare after publication of the final rule, industry data collection will begin on August 1, 2013. For the 2013 OPEN PAYMENTS program cycle, it will be abbreviated with only 5 months of data to be collected and reported, as compared to the 12-month cycles in subsequent years (January through December). Then, applicable manufacturers and applicable GPOs will submit the data to CMS by March 31, 2014, and CMS will make the data publicly available by September 30, 2014. CMS is developing an electronic system to facilitate the reporting process and the reported information will be easily aggregated, downloaded, and searchable on the program website.
The law specifies that, annually:
- Applicable manufacturers of covered drugs, devices, biologicals, and medical supplies must report payments or other transfers of value they make to physicians and teaching hospitals to CMS.
- Applicable manufacturers and applicable GPOs must report to CMS ownership or investment interests held by physicians or their immediate family members. Payments and other transfers of value to these physicians must also be reported.
- Applicable GPOs must report to CMS payments or other transfers of value made to physician owners or investors if they held ownership or an investment interest at any point during the reporting year.
CMS recommends that physicians maintain their own records of any interaction with applicable manufacturers and applicable GPOs. This can help facilitate the review of the data that is submitted about them. The law requires CMS to provide physicians and teaching hospitals at least 45 days to review and dispute the information related to them that was submitted by applicable manufacturers and applicable GPOs.
For more details, please click here.
Contact: Patrick Cucinelli, pcucinelli@leadingageny.org, 518-867-8827