Physician Payments Sunshine Act: Open Payments Registration Now Open?

In Baltimore, home of Centers for Medicare and Medicaid Services (CMS), we awoke to a dusting of additional snow. We also woke expecting to see new information about registration including definitions on “aggregate” on the Open Payments website that administers the Physician Payment Sunshine Act.

On February 7, 2014 CMS Announced that on February 18, 2014 Companies would be able to register for Phase I of Open Payments and at that time they will find out what the word “aggregate means” as they stated companies will be required to report aggregate payment data by March 31st 2014.

The webpage and the instructions have not changed since the announcement two weeks ago, there is no apparent new information. No splashy “open for business” page. The instructions provided are at best slightly confusing.

Today some companies who successfully go through step one of the phase one registration process should receive an email explaining how they find out about step 2 of the process which should include information about constitutes “aggregate”.

For those who cannot find how to register, as the instructions are listed under the Data Submission and Attestation page link, we have provided the instructions bellow.

Phase 1 Instructions

Step 1: New User Registration with CMS Enterprise Portal (EIDM Registration)

  • Go to the CMS Enterprise Portal (https://portal.cms.gov)
  • Select “New User Registration”
  • Read the Terms and Conditions and indicate your agreement by clicking “OK”
  • Fill out the requested fields on the “Your Information” page
  • Choose your user ID, password and challenge questions
  • On the “Registration Complete” page, click on “OK”
  • After clicking on “OK”, you will receive a confirmation email message that contains your user ID and a link to the CMS Enterprise Portal
  • Log back in to the CMS Enterprise Portal by clicking “Login to CMS Secure Portal” and entering your newly created user ID and password
  • Once logged in, click on “Request Application Access” on the right hand side of the CMS Enterprise Portal home page
  • Request access to Open Payments system by clicking on “Request New Application Access”
  • Select “Open Payments” from the drop down menu
  • A second drop down will then appear prompting you to select an Open Payments role in the system
  • Select “Open Payments User”
  • You will then see an acknowledgement message, click on “OK”
  • Then log out of the system by clicking “Log Out” in the upper right hand corner of the page
  • Log in to the CMS Enterprise Portal once again by clicking “Login to CMS Secure Portal” and entering your user ID and password
  • On the CMS Enterprise Portal home page you should now see a yellow button labeled “Open Payments” next to “My Portal” on the upper left hand side of the page
  • When you click on “Open Payments” you should have an option labeled “Registration” appear beneath it
  • Click on “Registration” to access details about the first step of Phase 1 of detailed data submission, CMS Enterprise Portal (EIDM Registration)

The Program Registration page provides details about the first step of Phase 1, CMS Enterprise Portal/EIDM registration. The second step of Phase 1 is described below:

Step 2: Aggregate Data Submission

After CMS Enterprise Portal/EIDM registration has been completed, the authorized official (or an authorized representative) will be directed to a webpage that will explain the requirements for Phase 1 data submission. The authorized official should download the data submission instruction document and the sample template available on this page. These materials are not available on the Open Payments website, and are only accessible after CMS registration is completed.

After completion, the authorized official or authorized representatives must submit the corporate profile information and aggregate 2013 payment data to CMS as instructed on the webpage and in the data submission instruction document.

When Phase 1 data has been submitted as instructed, the Open Payments Help Desk will reply directly to the submitter, confirming if the submitted data meets all requirements. If information is missing or improperly formatted, CMS will provide additional instructions on how to correct the data submission. 

For data submission details, review the Open Payments User Guide or the sections shown below. The materials posted under these sub-headings are available to assist reporting entities with the Phase 2 detailed data submission process.

Teleconference

CMS also stated in the release two weeks ago that there will be an announcement the next week (February 10 -14) on details for a future teleconference to further explain and answer questions about the two phase submission process.

As of this morning at 8:00am there is no upcoming events for Open Payments and no further information available on the website.

Update 02/18 12:07pm — The CMS enterprise portal does not support registration for Internet Explorer v. 11 (IE-11).  So use version 10 or below; you can use Chrome, Firefox or another browser. You will get stuck on the agree page on IE-11.

We will update you on further developments and what the meaning of the word aggregate is to CMS once we find out.

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