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Dispute and Correction


Dispute and Correction for Applicable Manufacturers and GPOs

Correct Disputed 2013 Data by October 31

Step-by-step instructions for the data correction process can be found on the Quick Reference Guide: Industry Record Review and Dispute Instructions.

By close of business Friday, October 31, applicable manufacturers and GPOs should make corrections to any 2013 disputed records, for publication on or before December 31, 2014. Data corrections can be performed in the Open Payments system at any time, but any corrective action taken prior to October 31 will be reflected in the refreshed data publication on or before December 31, 2014.

The noted disputes were initiated by physicians and teaching hospitals during the review and dispute period held earlier this year. Here is how the data will be displayed publicly on or before December 31, 2014:

  • Disputes that remain unresolved as of October 31, 2014 will display as disputed.
  • Any record that was disputed and resolved as of October 31, 2014 will display as undisputed.

Note: Any resolved records that result in a change to the covered recipient, and any records submitted to the Open Payments system for the first time, as well as any modifications to records currently on display, will NOT be published on or before the December 31 data refresh. That data will become available in a future data update. All data must undergo the review and dispute process in order to be published.

When an applicable manufacturer or GPO submits records regarding payments, other transfers of value, or physician ownership or investment interests to Open Payments, the associated physician or teaching hospital will have an opportunity to review the data that has been submitted about them prior to publication of the data. If the physician or teaching hospital finds discrepancies with the submitted data, the physician or teaching hospital can initiate a dispute.  

If a physician or teaching hospital initiates a dispute, an email notification will be sent to the individual that has been designated as the submitter. Once the dispute is reviewed, it can be resolved in one of three ways:

  1. Resolved – you update and resubmit the disputed data.
  2. Resolved, no change - indicates that you don’t agree with the dispute or have discussed the dispute with the physician or teaching hospital and determined that you didn’t need to change the data. Physicians and teaching hospitals can initiate a new dispute if they disagree with the “resolved, no change” status.
  3. Withdrawn – a physician or teaching hospital can withdraw a dispute initiated against a record.

When a dispute is resolved by making updates to a disputed record(s), you must resubmit and re-attest to the corrected record(s). Once this step is completed, the review and dispute status will automatically be updated to “resolved” in Open Payments. If you determine that no changes need to be made to the disputed record, the status will be updated to “resolved no change” in Open Payments. If a dispute cannot be resolved, then the latest, attested-to data you submitted will be published and marked under dispute.

Remember, it is up to you, the applicable manufacturer or GPO, to work directly with the physician or teaching hospital to resolve any disputes.  CMS is not responsible for mediating disputes.

The review and dispute process is 45 days. Once review and dispute closes, you have 15 days to resolve and submit corrections. Disputed data that is not resolved by the end of the 15-day period will be published on the public website, but will be marked as disputed.

For an overview or step-by-step instructions on the review and dispute process, acknowledging and resolving disputes, and the correction and resolution of disputed data, refer to the Resources page.