For several decades, Americans have had little trust in so-called Big Pharma. That is, many Americans have increased skepticism about the legitimacy of their large pharmaceutical companies and their dealings.
As a result, the government decided to institute a program to increase transparency between the medical industry and healthcare providers. This initiative became known as the Open Payments program.
The program discloses these payments on a publicly accessible site called the Center for Medicare & Medicaid Services (CMS). This website displays several types of information regarding these relationships.
However, many people wonder exactly how this works. What types of payments become reported? What regulations attend this program?
Background on the Open Payments Program
The Open Payments program stems from the Affordable Care Act. Although enacted in 2010, the first data collection occurred three years later, in 2013.
What are its specific requirements? The program requires manufacturers of covered drugs, devices, and medical supplies to track and report all payments and other valuable transfers. Similarly, manufacturers and group purchasing organizations (GPOs) must also report any ownership interests.
These groups must report to the CMS on a yearly basis. When they do, they must report transactions and several types of payments. Some of these payments include:
- Food and beverages
- Research payments
- Consulting fees
- Rental or facility fee meals
Typically, these payments fall under three major categories. We’ll discuss these categorizations in the next section.
CMS Open Payments Data Classifications
As we mentioned above, there are three primary ways to classify these financial reports. These three categories include general payments, research payments, and physical ownership information.
General payments are those disconnected from research agreements or protocols. So, to refer back to the list in the previous section, food and beverages would fall under this category. The same holds for travel/lodgings or facility meals.
As you may guess from the name, research payments pertain to transfers connected with a formal research agreement or protocol. For example, the CMS would include consulting fees as research payments. Gifts, however, would not fall under this classification.
Physician Ownership Information
This information includes any details about the ownership or investment interests that physicians have. Royalties and licensing may fall under this category depending on the circumstances.
The purpose of this category is to let you know what interests a group may serve. It gives you complete transparency as to where your healthcare or medicinal bills may go.
The Open Payments Program Schedule
As we’ve mentioned elsewhere, the Open Payments program requires groups to submit their reports on a yearly basis. To do so, these organizations must follow a schedule throughout the year.
What does this cycle look like? First, let’s start with its limits. It begins on January 1st and closes on December 31st.
In that time, there are four primary activities that organizations participate in. These include:
- Data Collection
- Data Submission
- Pre-publication Review/ Dispute and Correction
- Data Publication
The data collection period is when groups begin to compile their data for the annual report. Usually, this takes place during the first three months of the year. Towards the end of this quarter, you’ll submit your data.
Then, these groups begin the pre-publication review period. This typically lasts from April through May.
What do companies do during this review? This timeframe gives them the time and opportunity to dispute or correct any data. Other parties with whom they’ve worked may also contribute to these disputes and corrections.
On June 30th, this process comes to a close. Then, the data compiled is published on the CMS website.
You may think this would be the end of the program. However, the opposite turns out to be true.
Instead of wrapping up after June 30th, companies enter into a time of post-publication data review. This period lasts from July 1st to December 31st.
During this time, companies can review, affirm, and dispute data once again. If they must make changes, they’ll do so at this time.
On December 31st, the system winds to a close. This date represents the final day for a dispute opportunity.
Expansion of the CMS Open Payments Program
Under the SUPPORT Act, the Open Payments program expanded in 2021 to include several other medical classifications. These include:
- Nurse practitioners
- Physician assistants
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Anesthesiologist assistants
- Certified nurse-midwives
What does this mean for the program now? In short, it means that drug and medical device companies, along with their distributors, will soon begin reporting this newly relevant information to the CMS.
When will this take effect? Because the 2021 cycle is still underway, the new additions won’t take effect until 2022. By April of next year, providers will be able to review, affirm, or dispute any reported financial information about them.
Following the yearly cycle, this data will become published to the public by June 2022. If you’d like to learn more about how to dispute for such data works, check out https://www.medproid.com/public/solutions/disputeid today.
Why This Participation Matters
You may wonder how this program applies to you. The CMS indexed this data to make it easy for patients to conduct targeted searches in several categories. You can search for providers, teaching hospitals, medical specialties, etc.
When you register in the system, you can review data from providers and keep track of your provider’s information. While it’s completely voluntary, it can have many benefits for you as a patient.
We hope you enjoyed this article about open payments! If so, check out our other content today!