Yesterday, CMS’ Open Payments team held an informal question and answer session. Doug Brown, director of the data sharing and partnership group within the Center for Program Integrity at CMS, spoke on a number of topics that compliance professionals have spent the last year working through. He described what to expect in the coming weeks and technical issues with Open Payments.
Recently, CMS announced that applicable manufacturers and applicable group purchasing organizations (GPOs) are now able to register or recertify their registration in the Open Payments system and begin data submission for any payments or transfers of value that occurred in the 2014 calendar year.
As we previously reported: “All applicable manufacturers and GPOs must register or recertify their registration,” states CMS. “Applicable manufacturers and GPOs can also now submit corrected 2013 data (if needed) and submit their 2014 data to the Open Payments system.” March 31, 2015, is the deadline for all submissions.
Physicians and teaching hospitals may also now register in the system so they can be prepared to review any data that may be submitted about them. The review and dispute period for physicians and teaching hospitals is anticipated to start in April.
During the call, Brown stated that question and answer sessions will take place on a monthly basis to keep an open line of communication between the agency and stakeholders. The Open Payments website will list future dates and CMS will email the Open Payments listserv. Additionally, Brown noted that feedback from stakeholders has been helpful and that users of the database can expect numerous fixes in the “coming weeks”.
The latest revisions to Open Payments’ validated physicians list have been delayed and CMS is reprocessing all the records that are currently within the system to ensure fixes are implemented correctly online. While some records containing data published in the identified data set have failed, it is being reprocessed and CMS believes new updates will soon fix the problem. The agency intends on fixing all bugs as soon as possible, and once fixed, the updated refresher of the physician identifiers will be addressed. Updates may be available by next Friday, February 20.
CMS said the vast majority of data submitted are going through the normal process and will be matched to profiles in the system, or returned for a correction. Issues pointed out are “sparse,” but CMS has seen the calls to its helpdesk and hopes submissions will not slow down, despite problems that may occur.
Brown explained that Open Payments IDs assigned based on 2013 records were assigned a unique payment identifier for each payment received. Once CMS purged its system of records, it had to reprocess all of the payment files. In the process of validating that information, CMS had to reassign a new payment ID to these files. CMS does not believe this will have to happen again and is a one-time event, and stated that groups using the payment ID as the primary identifier for that record will be provided a crosswalk from CMS designed to guide users through the differences between what the payment ID was originally, to what it is currently. Brown said this will be fixed by Friday, February 13.
Callers reported a number of individual problems. One described an issue with CMS accepting nominations. If an officer nominates an individual, that person may have a problem accepting the nomination. Should this occur, CMS said the individual needs to register on Open Payments and then request that role be approved by the officer in the system.
Further, users do not have to get through 2013 activities in order to begin submitting 2014 data. With more media interest, people have become more aware of the program since last year’s dispute period. CMS does not want to be in the position where changes in the files call into question the validity of the data submitted last year, or cause more of a burden on teaching hospitals and physicians if they need to re-review data.
However, one user described uploading two files, eventually going through the submission phases, but found their information stuck in the validation phase for over 24 hours. CMS said this should not be happening and records should not be held up for that long. The caller was encouraged to contact the CMS helpdesk and the agency reminded listeners that manual entry is still a viable option for data reporting, possibly an important note for smaller groups submitting information.
Also of note, if time ran out before your question was addressed, you can either send your question to the Help Desk at openpayments@cms.hhs.gov, or save your question for a future Question & Answer session. CMS plans to conduct these sessions regularly each month, and will announce upcoming calls at least a week in advance. We will provide links to CMS’s future Q&As. Despite a number of individual problems with the system, it is encouraging that CMS is keeping an open line of communication through the data submission process this year.