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.
Teaching hospitals 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 teaching hospital representative wants to review data reported by industry relating to financial interactions industry has had with teaching hospitals.
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 teaching hospitals need to finish the registration steps. In order to review or dispute data submitted by industry for the 2013 reporting period, teaching hospitals 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 teaching hospital representative 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.
New Resources Available
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.
CMS developed multiple Quick Reference Guides. Guides include: how a teaching hospital 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, “teaching hospitals” are hospitals that received payment for Medicare direct graduate medical education (GME), inpatient prospective payment system (IPPS) indirect medical education (IME), or psychiatric hospital IME programs during the last calendar year for which such information is available.
Do Teaching Hospitals Have to Participate in Open Payments?
Teaching hospitals are not required to register with or send any information to Open Payments. However, to make sure CMS has the right information, we do encourage teaching hospitals to:
- Become familiar with the information that will be reported about teaching hospitals.
- Keep records of all payments and other transfers of value received from applicable manufacturers and applicable GPOs (while CMS has not yet developed specific resources for teaching hospitals to track transfers of value, staff of teaching hospitals 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 behalf of teaching hospitals.
- Work with applicable manufacturers and applicable GPOs to make sure the information submitted about teaching hospitals is correct.
CMS is committed to data accuracy, and will be closely monitoring this process to ensure integrity in the data posted. We encourage teaching hospital engagement in this process. Teaching hospitals that notice an inaccuracy can dispute data and work with applicable manufacturers and applicable GPOs to resolve disputes.
Applicable manufacturers and applicable GPOs may be audited based on activities that pertain to their compliance with Open Payments requirements to submit timely, accurate, and complete data. Audits and civil monetary penalties do not apply to teaching hospitals as a result of any reported activities.
Teaching Hospital Listing
For the 2013 Open Payments program cycle, click on the link below to access a listing of all teaching hospitals to be reported on (a version of the list is available in XLS format in the Downloads box at the bottom of this page):
- 2013 Open Payments Cycle: Teaching Hospital List [PDF, 797KB]
The teaching hospital list:
- Indicates all hospitals that have received a payment(s) under a Medicare direct graduate medical education (GME), inpatient hospital prospective payment system (IPPS) indirect medical education (IME) or psychiatric hospitals IME programs during the latest calendar year for which such data is available;
- Includes hospital names, addresses and taxpayer identification numbers (TINs);
- Is specific to a single Open Payments program cycle (i.e., 2013); and,
- Was posted approximately 90 days prior to the data collection period beginning for each Open Payments program cycle (May 3, 2013 for the 2013 Open Payments program cycle).
NEW: 2014 Teaching Hospital Listing
In addition, a teaching hospital list is now available for the 2014 Open Payments program cycle. Policy requires the listing to be available approximately 90 days prior to the data collection period beginning for each Open Payments program cycle (October 1 for all cycles after 2013). Note that this list should only be used for 2014 reporting (a version of the list is available in XLS format in the Downloads box at the bottom of this page), and should not be used for reporting for any other program cycle. For 2014 reporting, there are no changes to the submission file specifications.
- 2014 Open Payments Cycle: Teaching Hospital List [PDF, 797KB]
- Open Payments User Guide [July 2014] [PDF, 21MB]
- 2013 Open Payments Cycle: Teaching Hospital List [May 2013] [PDF, 797KB]
- 2013 Open Payments Cycle: Teaching Hospital List [May 2013, XLS] [ZIP, 104KB]
- 2013 Open Payments Program Year: Supplement to Teaching Hospital List [Oct 2013] [PDF, 674KB]
- 2014 Open Payments Cycle: Teaching Hospital List [October 2013] [PDF, 700KB]
- 2014 Open Payments Cycle: Teaching Hospital List [October 2013, XLS] [XLSX, 391KB]
- Phys./Teaching Hosp.: Phase 1 EIDM Registration Steps [June 2014] [PDF, 1MB]
- Quick Reference Guide: Teaching Hospital Registration Instructions [July 2014] [PDF, 125KB]
- Quick Reference Guide: Teaching Hospital Nomination Instructions [July 2014] [PDF, 116KB]
- Page last Modified: 07/16/2014 11:17 AM
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