As we’ve written numerous times now, the Centers for Medicare and Medicaid Services (CMS) split company submissions of data for Open Payments (the system for reporting for the Physician Payments Sunshine Act) into two phases for 2013 payments. Phase 2, which includes submission of detailed payment data and legal attestation of that data is supposed to start in May and extend for no fewer than 30 days. It’s nearing the end of May, and we have gotten no more clarity from CMS regarding this important step.
One of the reasons we are worried about CMS delaying the date for Phase 2 data submission is that physicians are relying on an already short window to review their data and dispute any information they believe to be incorrect.
CMS is running on a tight deadline this year. According to CMS, sometime in July, physicians will be able to review and dispute data prior to the public posting starting. No doctor wants the public scrutinizing payments that never even happened. Given the complex and expansive requirements imposed on pharmaceutical and device manufacturers from the Sunshine Act, mistakes in reporting are expected.
Any interruption in CMS’ timeline may run closely against the public access to data, scheduled for September 30, 2014.
Phase 2 will be much more labor intensive than Phase 1. We recently published an Inside Look into the Phase 2 process that explored the process for data submission.
CMS has released the first of three promised webinars on Phase 2. Phase 2 CSV & XML Tutorial: Preparing Data Files for Submission explains how to prepare data submissions using the data submission resources, specifically, using the CSV and XML Sample Files and XML Schema Definition (XSD document) to format data for upload into the Open Payments system.
The other tutorial videos are reportedly coming soon, despite the fact that Phase 2 will start any day now.