The Centers for Medicare and Medicaid Services (CMS) recently added several new entries to its Frequently Asked Questions (FAQs). Most of the questions relate to the new round of data that the agency published on June 30. CMS addresses the payment records and the status of disputed records among other topics, and promises “in the coming month…to present another new, very detailed search interface that will translate the large datasets into more detailed visualizations.”
“NEW” How is “de-identified” 2013 data being treated?
2013 data published last year included a set of “de-identified” records which removed payment recipients’ identifying information. This was done because CMS could not verify with full confidence that recipient identifiers were attributable to specific physicians or teaching hospitals and may also have included identifying information for multiple individuals.
Open Payments has since returned invalid records to the reporting entities for correction and has also enhanced the reporting system’s intake process to prevent invalid records from being ingested by the system. As a result, 2013 data records published as “de-identified” in 2014 will be published in 2015 with the recipients’ individual information included.
Key words: Open Payments, Sunshine Act (FAQ12372)
“NEW” In what formats is the data presented?
CMS delivers Open Payments data in a number of ways to accommodate different users and their interests:
- Search Tool: Site visitors can get immediate results using this standard search interface to find detailed information on individual physicians, teaching hospitals, or companies making payments.
- Data Explorer: Users can select a dataset then customize the view using filters, sorts, and other actions to create their own, targeted views of the data and visualizations such as charts and graphs.
- Data downloads: Users can download the data in comma-separated values (.csv) format, which allows users to open and explore the data using their own software on their own computer. With this option, the user must have robust data viewing software that allows for downloading and viewing data in large datasets.
Key words: Open Payments, Sunshine Act (FAQ12362)
“NEW” What if a physician or teaching hospital registered (or tried to register) prior to May 20, 2015, but was unable to dispute records until after May 20?
Review and dispute officially ended on May 20, 2015 for the 2014 reporting cycle. Any disputes initiated after this date will not be reflected in the June 30, 2015 data publication. These disputes and any subsequent correction to those data will be reflected in the next data refresh.
Key words: Open Payments, Sunshine Act
(FAQ12378)
“NEW” Did doctors and teaching hospitals have a chance to review the financial data reported about them?
Yes. During a 45-day physician and teaching hospital review and dispute period that ended on May 20, 2015, the dollar values and information about each transaction listed were available for review by doctors and teaching hospitals registered in the Open Payments system. They could confirm the information as correct or pursue corrections, via the dispute option, to remove, clarify, or adjust the information that had been attributed to them. This required 45-day review and dispute process affords the opportunity for physicians and teaching hospitals to review and dispute any data they feel is inaccurate or incomplete.
Key words: Open Payments, Sunshine Act (FAQ12376)
“NEW” Is any “de-identified” 2014 data being published?
No, no de-identified 2014 data is being published. Since last year, Open Payments has enhanced the reporting system’s matching logic (described above) and is now able to match most submitted records to valid physicians and teaching hospitals. In cases where a valid match is not found, the system returns the record to the submitter for correction.
Key words: Open Payments, Sunshine Act (FAQ12370)
“NEW” Are there any records that you are not publishing?
Yes. The Open Payments final rule provides that some research payments related to new product development, or new uses of an existing product, may be granted a delay in publication for up to four years, or until Food and Drug Administration (FDA) approval is received.
Key words: Open Payments, Sunshine Act (FAQ12374)
“NEW” Can a physician or teaching hospital still register in the Open Payments system and initiate a dispute after the May 20, 2015 deadline?
Physicians and teaching hospitals can register in CMS’ Enterprise Portal and the Open Payments system, and initiate disputes in the Open Payments system, at any point in the year. Please note, though, that the review and dispute period officially ended on May 20, 2015, for the 2014 reporting cycle, so any disputes initiated after this date will not be reflected in the June 30, 2015 data publication. These disputes will be reflected in the next data refresh reporting cycle. See the Open Payments System Quick Reference Guide – Review and Dispute Timing and Data Publication for detailed information on how disputes are shown in published records.
Key words: Open Payments, Sunshine Act (FAQ12392)
“NEW” Is there a methodology guide available providing technical details about the published data?
Yes, the Methodology Overview & Data Dictionary explains all of the technical specifications of the published data.
Key words: Open Payments, Sunshine Act (FAQ12386)
“NEW” When calculating number of payments a doctor received, should users count entries (rows) or tally the number of payment fields within each payment?
Each row indicates one payment, transfer of value, or ownership amount per doctor; counting rows should provide the total number of payments.
Key words: Open Payments, Sunshine Act (FAQ12368)
“NEW” How can disputes initiated by physicians and teaching hospitals be resolved?
Once the dispute is initiated, it can be resolved in one of three ways:
- Resolved – Disputed data is updated and then resubmitted and re-attested to by the applicable manufacturer or GPO.
- Resolved, no change – Indicates that both the applicable manufacturer or GPO discussed the dispute with the physician or teaching hospital, and both parties determined that no change in the data was necessary. Physicians and teaching hospitals can initiate a new dispute if they disagree with the “resolved, no change” status.
- Withdrawn – A physician or teaching hospital can remove a dispute opened on a record.
Key words: Open Payments, Sunshine Act (FAQ12388)
“NEW” What happens if physicians or teaching hospitals initiated disputes with the reported data before/after the review and dispute period ended on May 20, 2015?
The status of a dispute on a record has several effects on what data is published. Details of how disputes are shown in published records are explained in the Open Payments System Quick Reference Guide – Review and Dispute Timing and Data Publication.
Key words: Open Payments, Sunshine Act (FAQ12390)
“NEW” My organization already downloaded the 2013 data last year; should we download just the new 2014 data this year?
CMS recommends that you re-download the 2013 data this year, in addition to downloading the new 2014 data. The 2013 data that’s being published on June 30 includes a number of additional records that were not included in the previous publication or were included only in de-identified form. Additionally, enhancements made since last data publication changed the previous system-assigned unique identifiers like Physician_Profile_ID, Record_ID, and Teaching_Hospital_ID. That means that identifiers in this year’s publication will not match identifiers in last year’s publication. For example, profile ID 123 used for Dr. John Smith in the last data publication is no longer associated with Dr. John Smith. Re-downloading the 2013 data will ensure that the profile ID your system has for 2013 matches the profile ID for 2014 data. CMS does not anticipate changing the system-assigned unique identifiers again.
Key words: Open Payments, Sunshine Act (FAQ12382)
“NEW” What is CMS doing to make sure this information is friendly for consumers?
Since first publishing Open Payments data in September 2013, CMS has made many enhancements to the tools available to search and manipulate the data. Shortly after the initial data publication, CMS launched a data search tool to allow for consumer-friendly data searches that allows users to search for their personal physician, or search on criteria such as specialty, location, or types of payments received.
Continuing on that path, CMS is providing summary graphics of key data points on https://openpaymentsdata.cms.gov/. This new data dashboard will also be available in printable format. Additionally, in the coming month, CMS will present another new, very detailed search interface that will translate the large datasets into more detailed visualizations.
The program does not make assumptions or draw conclusions about the information reported, and CMS is directing consumers who may have questions about the information on the website to use it as one of the many discussion points in their doctor-patient relationship.
Key words: Open Payments, Sunshine Act (FAQ12394)
“NEW” How often is Open Payments data refreshed or updated?
CMS will collect and publish this data every year. September 30, 2014, was the first publication of this data; it was then refreshed for the first time on December 19, 2014. This year, and for all years after, data publication is on June 30. CMS will also refresh the data once annually, after the initial publication.
Key words: Open Payments, Sunshine Act (FAQ12380)
“NEW” Is CMS planning to provide any type of data summary sheets?
CMS is providing summary graphics of key data points on https://openpaymentsdata.cms.gov/. This new data dashboard will also be available in printable format. Besides that, CMS is not providing any other summary presentations of the data. The data is publically accessible and available for consumers and researchers to extract as they see fit.
Key words: Open Payments, Sunshine Act (FAQ12364)
“NEW” How many records did CMS release on June 30, 2015? What is the value of those records?
For 2014, the data contains 11.4 million records, totaling $6.49 billion. That means that over the program’s entire lifespan, 15.7 million records of payments, other transfers of value, and ownership or investment interests are reported on the Open Payments website, totaling $9.9 billion. These records are attributable to over 600,000 physicians and more than 1,100 teaching hospitals.
Key words: Open Payments, Sunshine Act (FAQ12358)