The Centers for Medicare and Medicaid Services (CMS) has hosted two Sunshine Act webinars this week for physicians and other covered recipients. The presentation served as an introduction to the Open Payments system, but did not provide physicians any set dates in terms of registration in order to look over their payment data.
The latest timeline is as follows:
The timeline suggests that physician and teaching hospitals would be able to register with CMS today, but that is not the case. CMS notes that more information about Phase 2 will follow “within the next few weeks.” They also stated that more information for physicians would follow at that time. Manufacturers have a minimum of 30 days to submit their information once Phase 2 opens.
Physician Review
The Open Payments system opens for covered recipient registration for the 2013 program year following the conclusion of Phase 2 of industry registration and data submission. As noted above, we don’t yet know when that will be.
Once the system is open for physician registration (following the conclusion of Phase 2 of industry registration and data submission later this year), CMS notes that there is no deadline for covered recipient registration. Furthermore, there is no start date of physician registration in subsequent years; registration is ongoing.
CMS has stated that once the final stages of Phase 2 data submission are completed by industry, CMS will then notify covered recipients “through various means” to register, and go into the Open Payments website and review the information submitted by industry.
During the Question and Answer session, someone asked: “Will the physician registration process be similar to phase 1 process?” CMS responded that yes, physicians must go into the CMS enterprise portal to register. The portal is the “front door, then you continue on to registration,” CMS stated. Thus, the process is not instantaneous, and may entail a waiting period before physicians are able to actually get in to the system and review their data.
During the registration process, CMS clarified that social security numbers are not required, but help to identify and verify a physician’s identity.
CMS encouraged the covered recipients to use CMS’ app, “Open Payments Mobile for Physicians.” They stated that the tool allows the user to track payments and other transfers of value in real time. Furthermore, covered recipients would be able use their information as a reference in the case of disputes.
Issue: Under the General Payments Data-Mapping Rules, how does an applicable manufacturer properly record a series of payments made to the same covered entity for Travel and Lodging when the Data-Submission rules only permit one state to be entered in line #39?
Facts:
An applicable manufacture paid for three trips taken by a covered entity physician. The physician traveled to three different states (KS, MI, MO) on three different dates, and was reimbursed for the amount he spent on travel and lodging by the applicable manufacture.
Rules:
Data element #33 provides “the ‘total amount of payment’ should be tied to a singular transaction (items listed in the “Nature of Payment” line 37).” The “Nature of Payment” (line 37) requires an applicable manufacture to denote “7” when the transaction was made for “travel and lodging”. When “travel and lodging” payments are selected, Line 39 & 40 require an applicable manufacture include the city and state of travel. Line #39 is limited to “2 characters” and line #40 is limited to 20 characters. Line #34 states that when an applicable manufacturer is reporting a “series of payments or an aggregate set of payments” the applicable manufacture is to record the date of the first payment in line #34 and the actual number of payments made to the covered entity in line #35 for the “Total Amount of Payment” data recorded in data-element #33.
Analysis and Questions:
If an applicable manufacture paid for three trips taken by a covered entity, does the multiple trips qualify as a “series of payments or an aggregate set of payments” when recording? If so, how can an applicable manufacturer record both: (a) the total amount and number of payments made to a coverer recipient; and (2) record the three different states the covered recipient traveled to in line #39, when that data-element is limited to “2 characters” and line #40 is limited to 20 characters?
Alternatively, when it comes to multiple trips (travel and lodging) by one covered entity, is the proper course of action not to aggregate the amounts of the “nature of payment” in this instance, but rather parse-out each trip individually and record as a single transaction for the same doctor on three different excel/CSV rows?
Thank you.