CMS Releases 2016 Open Payments Teaching Hospital List

As they did on October 1^st last year, yesterday, the Centers for Medicare and Medicaid Services (CMS) released an updated Teaching Hospital list and increased (slightly) reporting thresholds for the next year’s reporting cycle.

In looking at the new hospital file, CMS has added to its list—the agency included 1,203 last year, it is up to 1,222 this year. In terms of a “de minimis” threshold, if a payment or other transfer of value is less than $10.22 ($10.21 for 2015; $10.18 for 2014), unless the aggregate amount transferred to, requested by, or designated on behalf of a covered recipient exceeds $102.19 in a calendar year ($102.07 for 2013; $101.75 for 2014), it is excluded from the reporting requirements under Open Payments.

The Physician Payments Sunshine Act (Open Payments) requires drug and device manufacturers to report direct and indirect payments or other transfers of value made to physicians and teaching hospitals. Physicians and teaching hospitals are collectively known as covered recipients. In order to assist manufacturers in identifying teaching hospitals, CMS stated that it would publish a list of the relevant teaching hospitals by October 1 of the preceding reporting period.

The 2016 list includes the same information categories as the 2015 Teaching Hospital List (i.e. taxpayer identification number (“TIN”), teaching hospital’s common business name, legal business name, address. Applicable manufacturers and applicable group purchasing organizations should use this list for the January 1 through December 31, 2016 data collection period. 

The list is an important resource to assist manufacturers when determining if they are required to report payments or other transfers of value made to a hospital.

For the 2016 Open Payments program cycle (data collected from January 1, 2016 through December 31, 2016), view the updated listing of teaching hospitals: PDF and XLSX

Below is an analysis of those hospitals who are no longer on the list from 2015 and added in 2016.   Some included name changes.

Unique for 2015                                                                         Unique for 2016