OPEN PAYMENTS Creating public transparency into industry- physician financial relationships 13 th Annual Transparency & Aggregate Spend Forum Robin Usi Acting Director Data Sharing & Partnership Group August 13, 2019 CMS Disclaimer: This information is a summary of sections of the NPPTP. This information is a summary of the final rule implementing the National Physicians Payment Transparency Program (Medicare, Medicaid, Children's Health Insurance Programs; Transparency Reports and Reporting of Physician Ownership or Investment Interests [CMS-5060-F], codified at 42 CFR Parts 402 and 403) The summary is not intended to take the place of the final rule which is the official source for information on the program.
Program Year 2018 Timeline
Program Year 2018 Data Publication • On June 28, 2019 the Program Year 2018 data was published along with newly submitted and updated payment records from prior program years (2013-2017) • Applicable manufacturers and group purchasing organizations (GPOs) collectively reported 11.40 million publishable records , amounting to $9.35 billion payments and ownership and investment interests made to covered recipients for Program Year 2018 • Payments are reported across three payment categories • General Payments • Research Payments • Ownership & Investment interests held by physicians or their immediate family members
The Data – Program Year 2018 Total U.S. Dollar Value Total Records Published $9.35 Billion 11.40 Million Research Payments Ownership & Investment General Payments $4.93 Billion $1.42 billion $3.00 Billion
Program Year 2018 Payment Categories Ownership & Investment Interests 15% General Payments 32% Research Payments 53%
The Data – Program Years 2017 & 2018 Program Years 2017 and 2018 by payment categories 6 Billions $5.10 $4.93 5 4 $3.00 $2.90 3 2 $1.42 $0.98 1 0 Program Year 2017 Program Year 2018 General Payments Research Payments Ownership & Investment Interests
Program Year 2018 Top Five Nature of Payment Categories – Dollar Value $1.20 Billions $1.09 $1.00 $0.80 $0.61 $0.60 $0.46 $0.40 $0.24 $0.19 $0.20 $0.00 Royalty or License Compensation for Consulting Fee Food and Beverage Travel and Lodging services other than consulting Nature of Payment Category
Program Year 2018 Top Five Nature of Payment Categories – Number of Records 10 9.50 Millions 9 8 7 6 5 4 3 2 0.59 1 0.25 0.21 0.14 0 Food and Beverage Travel and Lodging Compensation for Education Consulting Fee Services Other than Consulting Record Value of Payment Category
Program Year 2018 Top Five Nature of Payment Categories – Number of Records* 700 Thousands 585.65 600 500 400 245.59 300 210.57 200 140.40 73.06 100 0 Travel and Lodging Compensation for Education Consulting Fee Gift Services Other than Consulting Record Value of Payment Category *Excluding Food and Beverage Category
The Data – All Program Years Total Records Published Total U.S. Dollar Value 64.77 Million $43.22 Billion Research Payments Ownership & Investment General Payments $26.57 Billion $1.42 Billion $15.23 Billion
The Data – Program Years 2014 – 2018 6 Billions $5.10 $4.93 $4.93 $4.77 $4.72 5 4 $3.00 $2.89 $2.70 $2.90 $2.73 3 2 $1.42 $1.18 $1.09 $1.12 $0.98 1 0 2014 2015 2016 2017 2018 General Payments Research Payments Ownership & Investment Interests
Open Payments Survey • Recently the Open Payments team began offering a user survey on the search tool site • The survey’s goal is to get user feedback on the search tool including what brought them to the site and if they found what they are looking for. • Currently Survey 3.0 is available on the search tool site
Summer 2019 System Enhancements • Physician Matching • New ability to validate physician information and download results at any time during or outside the submission period • Compliance Portal • Functionality for the CMS Open Payments Compliance team to upload, maintain and track all compliance related communications sent to reporting entities • System Generated Emails • Ability to view all system generated email messages associated with each organization
Winter 2020 System Enhancemen ts • Drug Data Validation • Associated drug information will be checked and validated against FDA’s drug listing directory data • Zip Code Validation • Verification that entered zip codes are valid within the boundary of the selected state • License Expiration • Will ensure that payments associated with physician licenses which expired prior to the start of the Open Payments program are rejected • Errors and Warnings • Errors and warnings notifications will be added to the Record Overview page to provide immediate matching feedback
What we’ve been up to • Annual Physician Mail Campaign • Ran throughout the pre-publication Review & Dispute period • Letters sent to approximately 54,000 physicians • Help Desk – Physician Outreach • Currently conducting outreach to physicians who need to complete the vetting process within Open Payments in an effort to help the physicians gain access to the program • Compliance Outreach • Submission reminders • Late Attestation reminders
SUPPORT for Patients and Communities Act • The SUPPORT Act was passed in the fall of 2018 and included Open Payments provisions • Covered Recipients to include: • Physician Assistants • Nurse Practitioners • Clinical Nurse Specialists • Certified Registered Nurse Anesthetists • Certified Nurse-midwives • Publication of National Provider Identifiers (NPIs)
Open Payments Expansion Provisions – CMS Proposed Changes • The CMS proposed changes to Open Payments appear as a rider to the 2020 Physician Fee Schedule (PFS) • Proposed changes: • Three new Nature of Payment Categories: • Debt Forgiveness • Long term medical supply or device loan • Acquisitions • Consolidation of the two medical education program Nature of Payment Categories into one • Proposal to standardize data on reported products • Additional reporting requirements for the ‘device identifier’ component of the unique device identifier for devices and medical supplies
Information and Your Input • The changes to the Open Payments program appear as a rider on to the 2020 Physician Fee Schedule • The Physician Fee Schedule Proposed Rule with comment period was placed on display at the Federal Register on July 29, 2019. • CMS is accepting comments on the proposed rule until September 27, 2019. • More information and access to the proposed rule is available on the Open Payments Law and Policy Page
Program Timeline Reminders • November 15, 2019 • Deadline for corrections to undisputed records • Deadline to remove any previous delay in publication requests • December 31, 2019 Covered Recipient Review & Dispute Deadline • – Covered recipients have until the end of the calendar year to review and if necessary initiate a dispute on Program Year 2018 or newly published data • January 2020 • Data Refresh
Stay Connected • VISIT THE OPEN PAYMENTS WEBSITE o For resources including Open Payments FAQs and more information about the program visit https://cms.gov/openpayments • SUBSCRIBE TO THE LISTSERV o Receive program updates through the Open Payments listserv o Subscribe at our Contact Us page • SEARCH THE DATA o Access the Open Payments data at https://openpaymentsdata.cms.gov • HAVE QUESTIONS OR NEED HELP? o Email: openpayments@cms.hhs.gov o Call: 1-855-326-8366 (TTY Line: 1-844-649-2766) o The help desk is currently open from 9:00am to 5:00pm (ET) 20
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