On February 13, 2019, the Centers for Medicare & Medicaid Services (CMS) Open Payments team held a webinar during which it went over an overview of system enhancements and information related to Program Year 2018 Data Submission for reporting entities.
Data Refresh
The webinar started out with a brief discussion about the Program Year 2017 Data Refresh. In January 2019, CMS refreshed the Open Payments Program Year 2017 data to reflect changes that were made after the initial publication of the data.
During the refresh, CMS made changes to non-disputed records that were made on or before November 15, 2018; removed dispute indicators for previously disputed records that were resolved prior to December 31, 2018; and removed records deleted on or before December 31, 2018 from the Open Payments database.
CMS did not include records submitted for the first time after the close of Program Year 2017 submission window (March 31, 2018) nor did it include any records that were disputed and for which dispute resolution resulted in a change to the covered recipient.
After the refresh, there were a total of 11.27 million records published, amounting to $8.31 billion. Broken down, general payments amounted to $2.81 billion, research payments totaled $4.56 billion, and ownership and investment equaled $932 million.
Program Year 2018 Timeline
The data collection portion of Program Year 2018 closed on December 31, 2019, and we are currently in the middle of the time to submit payment data. All payment data should be submitted by the close of this period, March 31, 2019. Then, beginning April 1, 2019, through May 15, 2019, physicians and teaching hospitals are able to review and dispute the data, and May 16, 2019 through May 30, 2019, applicable manufacturers and GPOs are able to review and correct the data. Then, the data is expected to be displayed on the CMS public website no later than June 30, 2019.
Reporting Entity Recertification
Reporting entities that previously registered in a calendar year must recertify in order to perform any Open Payments system functions. As a reminder, recertification can only be performed by an active user who holds an officer role; if a reporting entity does not have an active officer, that reporting entity should contact the Open Payments Help Desk for assistance.
Outdated or inaccurate reporting entity profile information can be updated during the recertification process, but changes to the entity’s Legal Name, Tax Identification Number (TIN), or DUNS number will require re-vetting of the entity.
2019 System Enhancements
For 2019, CMS updated the bulk file validation to match those of the graphic user interface for validating physician taxonomy codes. CMS also updated the presentation of the expired license warning and added the ability to filter records based on the warning status.
When it comes to usability enhancements, CMS made changes to reduce the amount of scrolling and clicking needed when editing a record via the graphic user interface. For example, the payment record layout was updated to facilitate data entry and review, including reducing the amount of scrolling required and CMS introduced the Payment Navigation Bar to provide a visual indicator of the page the user is on within the record. The Payment Navigation Bar allows users to navigate to each page out of order, assuming there are no errors on the user’s current page.
CMS made additional enhancements as well, including adding a new section on the submissions page to display file processing status, prevent uploading a file with the same attributes while the file is processing, the ability to delete records directly from the Review and Dispute page, and performance enhancements expected to reduce the processing time of final submission.
Delay in Publication
By way of reminder, delay in publication of payments may be requested and granted for up to four years. This means the four-year limit has not been reached for payments made in the 2014 calendar year. Records with previously requested delays that are no longer eligible for delay status will be identified on the record listing page with a “Delay Limit Reached” status and if there are attempts to renew a publication delay for a record not eligible, an error message will pop up.
Question and Answer Session
The webinar concluded with a question and answer session. Some of the questions asked and answered are included below.
- How do you deactivate an applicable manufacturer?
- You do not deactivate, you just do not recertify.
- How does one handle the specialist taxonomy issue, as many physicians still use specialist?
- There is not much CMS can do, use the one that most closely matches.
- If a physician’s practice lists multiple taxonomies, which one should be reported?
- The one that is most relevant.
- If we submit a correction to 2017 data, does it get published on June 30th?
- No, it will be published with the next refresh publication date. New records will be reflected next June.
- How do you report if a physician has passed away?
- Their license will be active for the reporting year.
- If a manufacturer sells through a distributor, do they still need to file?
- Yes.
- After acquisition, do we have to keep re-registering the old entity?
- No,
Next Steps
New Reporting Entity
If you are a new reporting entity, you will need to register in EIDM and request access to the Open Payments system. From there, you will need to register yourself and the reporting entity (if applicable) in the Open Payments system and assign user roles. You must submit Program Year 2018 data by March 31, 2019 (if applicable) and begin to college Program Year 2019 payment data for reporting in early 2020.
Returning Reporting Entity
If you are a returning reporting entity, ensure your EIDM account is active and recertify your reporting entity information, including review and dispute contact information. Confirm all user roles and submit Program Year 2018 data by March 31, 2019. You should be collecting Program Year 2019 payment data for reporting in early 2020.