Key Points

• Physicians are not required to register or take any action  
• If you choose to register to view data that may have been reported about you, you must complete a 2-step registration process (details below) in order to access the Open Payments System, review any data and initiate any disputes, if necessary
• Even if you do not expect any data to be posted about you, you may still access the Open Payments System to confirm that fact

If you do not plan to register to access the Open Payments System, you may STOP HERE   

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THE OPEN PAYMENTS SYSTEM
Open Payments is a national disclosure program intended to promote transparency in financial relationships among the healthcare industry.  It was established by the Physician Payments Sunshine Act, a part of the Affordable Care Act.  The Open Payments program publishes data regarding payments or other transfers of value between healthcare manufacturers and group purchasing organizations (GPOs) and physicians and teaching hospitals. 

Under the law, the following data must be reported to CMS annually by manufacturers and GPOs and made available to the public through the CMS website:   

• Payments and other transfers of value made by manufacturers of drugs, devices, biologicals, and medical supplies to physicians and/or teaching hospitals
• Certain ownership or investment interests held by physicians or their immediate family members
• Payments or other transfers of value made to physician owners or investors if they held ownership or an investment interest at any point during the reporting year

All data for the 2013 calendar year will be posted on the CMS website on September 30, 2014.

Physicians have no reporting or registration obligations under the Open Payments program, but may wish to review any data reported about them to ensure the accuracy of the information or, in the alternative, confirm that no data has been reported.  Physicians are also afforded the opportunity to dispute and correct any information they believe is inaccurate.   

Physicians may register to view and dispute 2013 data at any time during the remainder of calendar year 2014.  However, the initial physician data review and dispute period started on July 14, 2014 and ends August 27, 2014.   If a physician initiates a dispute during the period July 14-August 27, the dispute will be reflected in the data made public on September 30th with the notation "Under Dispute."  During the period July 14-September 11, manufacturers and GPOs will endeavor to resolve any initiated disputes and make corrections where necessary in advance of the September 30th publication date.  Disputes initiated after August 27th will be accepted but may not be reflected in the data made public on September 30th.   

In order to register to review and dispute, where necessary, any inaccurate data reported on the Open Payments System, physicians should utilize a 2-step registration process, as follows: 

STEP ONE:   REGISTER WITH THE CMS ENTERPRISE IDENTITY MANAGEMENT SYSTEM (EIDM) 

• This step is required in order to establish an Enterprise Portal User Account and request access to the Open Payments System.  This registration includes an identity proofing process that utilizes Experian in its role as an outside verification service provider.  Registration with EIDM is mandatory only if you want to review the physician data that may be reported about you.  
• Use the following link:  https://portal.cms.gov
• On the right hand side of the screen, under CMS Secure Portal, click on "New User Registration"
• Once your registration is complete and your online registration session has ended, you will receive a confirmation email with your assigned User ID and password and a link to return to the CMS Secure Portal.  

Helpful Hints on establishing EIDM credentials:  Users who already have EIDM credentials do not need to re-register.   EIDM will lock your user account if you do not log in to your account for 60 or more days.  When you login after 60 days, the system will display the “Unlock my Account” view. To unlock your account, enter your user ID and correctly answer all challenge questions. Then enter your new password in the input fields of “New Password” and “Confirm New Password” to unlock your account. If you are still unable to reactivate your account, contact the Open Payments Help Desk at [email protected] or call 1-855-326-8366.  EIDM will automatically deactivate any user that has not logged in for 180 days or more. Once the user’s account has been disabled, the user will not be able to access the CMS application(s). You can contact the Open Payments Help Desk at [email protected] or call 1-855-326-8366 to reactivate your account after 180 days of inactivity.

STEP TWO:  REQUEST ACCESS TO THE OPEN PAYMENTS SYSTEM

• Use the following link:  https://portal.cms.gov  (same website used in Step One)
• On the right hand side of the screen, under CMS Secure Portal, click on "Login to CMS Secure Portal"
• Accept Terms and Conditions
• Log in using the user name and password that was emailed to you following completion of Step One
• Under Request Application Process, click "Request Access Now"
• Select "Request New Application Access"
• Select the Application Description and the Role
• Under Application Description, select "Open Payments"
• Under Role, select "Applicable Manufacturer, GPO, Physician, or Teaching Hospital"
• Complete Identity Verification Process
• Once your request for access is successful, you will need to logout and log back in again
• Once you log back in, you will see an Open Payments tab in the menu bar at the top of the screen

Physicians may designate an authorized representative to take certain actions on their behalf.  Each physician is able to designate only one authorized representative, who can be another physician, an office manager, or a practice manager.  The registering physician can assign access levels for their authorized representative within the Open Payments System. 

TO REVIEW AND DISPUTE REPORTED INFORMATION THAT YOU BELIEVE TO BE INACCURATE

• From within the Open Payments System, select the “Review and Dispute” tab.
• Select the physician or teaching hospital name, as applicable, and program year for which you wish to review data
• Click the “Show Records” button.  If there are records that have been reported for you or a teaching hospital you represent, you will be directed to the “Review and Dispute” page.  If there are no records associated with you or your organization, you will receive a notification indicating there are no records to review.
• On the “Review and Dispute” page, you will see a list of all submitted records for the selected physician or teaching hospital.  You may filter the records by using the filtering tools in the search box.
• Review your records by scrolling to the right and selecting the “View” link under the “View Record” column. 
• Based on your review of the information, you have the option to perform the following actions on each record:
• Affirm:  confirms the payment or other transfer of value as identified. You may affirm a record as long as the selected record does not have any disputes in an initiated or acknowledged status.
• Dispute:  disputes the payment or other transfer of value reported.
• Withdraw:  withdraws a dispute you previously initiated.
• To perform one of these actions, select the desired record(s) and click on the corresponding button on the Review and Dispute page (e.g., Affirm Record, Dispute Record, or Withdraw Dispute).  Follow the on-screen text to complete the desired action.  
• If you dispute a record, you will be required to provide a reason for the dispute.  All comments submitted as your reasons for dispute will be made available to the relevant manufacturer or GPO.    

WHAT HAPPENS NEXT? 

Data corrections may be made by drug manufacturers or GPOs at any time and the corrections will be posted along with the next data refresh.  CMS will update data from the current and previous year at least once annually, in addition to the initial data publication (for this year, September 30, 2014).  In the cases where a dispute cannot be resolved, the latest, attested-to data submitted by the manufacturer or GPO will be published and marked "Under Dispute."  CMS will monitor disputes and resolutions to keep track of how often disputes are reported by physicians and teaching hospitals and the volume of unresolved disputes.

FOR MORE INFORMATION

CMS Website:  http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Physicians.html

Open Payments Step-by-Step CMS Enterprise Portal Registration for Physicians and Teaching Hospitals: https://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Downloads/Phys-Teaching-Hosp-Phase-1-EIDM-Registration-Steps-%5BJune-2014%5D.pdf