Review and Dispute Period: July 14 – August 27, 2014
Do you want to review Open Payments data reported about you before it is available to the public? Get started now by registering in CMS’ Enterprise Portal.
Physicians are encouraged to register in CMS’ Enterprise Portal (Enterprise Identification Management system – EIDM) and the Open Payments system in order to view the data reported by industry that will be made public on September 30, 2014.
Registration is a voluntary process, but it is required if a physician wants to review data reported by industry relating to financial interactions industry has had with physicians.
Registration for physicians and teaching hospitals will be conducted in two phases for this first Open Payments reporting year. There is no official end date for when physicians need to finish the registration steps. In order to review or dispute data submitted by industry for the 2013 reporting period, physicians must be registered – and have reviewed any data reported about them – on or before August 27, 2014, the end of the initial 45-day review and dispute period. Please keep in mind that identity verification can take some time; CMS recommends completing the registration process as soon as possible and not waiting until the end of this initial 45-day review and dispute period.
Two Phases of Registration
- Register in the CMS Portal - HAPPENING NOW: Register in CMS’ Enterprise Portal (the gateway to EIDM). Use the Phase 1 Step-by-Step CMS Enterprise Portal Registration for Physicians and Teaching Hospitals presentation for guidance on how to complete this first portion of the registration.
- Register in the Open Payments System – HAPPENING NOW: Register in the Open Payments system to complete the registration process and have the opportunity to review and dispute data submitted by applicable manufacturers and applicable group purchasing organizations (GPOs) prior to public posting. Use the Quick Reference Guide on how a physician can register in the Open Payments system.
- Review – July 14 through August 27, 2014: If you have any concerns about the data's accuracy, this is the time to dispute and correct the data submitted by industry. Use the Quick Reference Guide on how to initiate and dispute a record in the Open Payments system. Share the Quick Reference Guide on how to accept or reject a nomination with individuals that will be your Authorized Representative.
Note: Any data that is disputed, if not corrected by industry, will still be made public but will be marked as disputed. Learn more about the review and dispute process.
The Open Payments User Guide has been extensively updated to provide industry, physicians, and teaching hospitals with a comprehensive understanding of Open Payments system and requirements. New chapters include: physician and teaching hospital registration in the Open Payments system, and review and dispute functionality. It can also be downloaded on the Open Payments Fact Sheets and User Guides web page.
Look up your NPI on the National Plan & Provider Enumeration System website. Use the Taxonomy Crosswalk document, also available in the Related Links section at the bottom of this page, to look up specialty codes.
CMS developed multiple Quick Reference Guides. Guides include: how a physician can register in the Open Payments system, how to dispute a record, and how an authorized representative can accept or reject a nomination.
For assistance registering in CMS’ Enterprise Portal (the gateway to CMS’ Enterprise Identification Management system (EIDM)), view the instructional presentation on steps to complete EIDM registration.
For the purposes of Open Payments, a “physician” is any of the following types of professionals that are legally authorized by the state to practice, regardless of whether they are Medicare, Medicaid, or Children's health Insurance Program (CHIP) providers:
- Doctors of medicine or osteopathy
- Doctors of dental medicine or dental surgery
- Doctors of podiatric medicine
- Doctors of optometry
Note: Medical residents are excluded from the definition of physicians for the purpose of this program.
Do Physicians Have to Participate in Open Payments?
Physicians are not required to register with or send any information to Open Payments. However, to make sure we have the right information, we do encourage physicians to:
- Become familiar with the information that will be reported about physicians.
- Keep records of all payments and other transfers of value received from applicable manufacturers or applicable GPOs (physicians can use the Open Payments Mobile for Physicians app to track payments and other transfers of value they receive from applicable manufacturers and applicable GPOs throughout the year).
- Register with CMS’ Open Payments system and subscribe to the listserv to receive updates regarding the program.
- Look at the information applicable manufacturers and applicable GPOs submit on physician’s behalf.
- Work with applicable manufacturers and applicable GPOs to make sure the information submitted about them is correct.
CMS is committed to data accuracy, and will be closely monitoring this process to ensure integrity in the data posted. We encourage physicians’ engagement in this process. Physicians who notice an inaccuracy will be able to dispute the information and work with applicable manufacturers and applicable GPOs to resolve disputes.
Two Continuing Medical Education Activities Available
Also available for physicians to learn more about Open Payments is Continuing Medical Education (CME) activity. Two such activities are available and accessible via Medscape; both are accredited by the Accreditation Council for Continuing Medical Education:
- “Are You Ready for the National Physician Payment Transparency Program?” Through the activity, participants will learn more about Open Payments, the steps involved in collecting and reporting physician data, key dates for implementation, and actions they can take to verify physician information in advance of website publication.
- “The Physician Payment Transparency Program and Your Practice” Through this activity, participants will be able to identify opportunities for physicians to review transfers of value attributed to them and differentiate types of transfers of value that will or will not be reported under Open Payments.
Medscape accounts are free and users do not have to be health care professionals to register. Registration can be found on the Medscape website www.medscape.com.
- Open Payments User Guide [July 2014] [PDF, 21MB]
- Program Overview for Physicians [August 2013] [PDF, 269KB]
- Program Overview for Patients [August 2013] [PDF, 222KB]
- Phys./Teaching Hosp.: Phase 1 EIDM Registration Steps [June 2014] [PDF, 1MB]
- Quick Reference Guide: Physician Registration Instructions [July 2014] [PDF, 118KB]
- Quick Reference Guide: Physician Authorized Representative Instructions [July 2014] [PDF, 115KB]
- Page last Modified: 07/16/2014 9:14 AM
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