As manufacturers and group purchasing organizations (GPOs) get ready for Phase 2 of Open Payments (formerly, the Physician Payments Sunshine Act), physicians and teaching hospitals should be aware that a voluntary registration process to enable them to review data submitted by manufacturers and GPOs through Open Payments will soon follow.
For the 2013 reporting year only, the Centers for Medicare & Medicaid Services (CMS) bifurcated the submission of Open Payments data by manufacturers and GPOs into two separate phases. Phase 1, involving submission of aggregate data for the 2013 reporting year, was completed as of March 31, 2014. Phase 2, involving submission of detailed data on physician ownership and payments made to physicians or teaching hospitals, is projected to begin in May 2014 and will last for at least 30 days.
While neither physicians nor teaching hospitals are required to submit data through Open Payments, or register with Open Payments, CMS encourages them to become familiar with the information that will be reported and to register with Open Payments to review the data submitted by manufacturers and GPOs on their behalf. This review will help physicians and teaching hospitals to ensure that their relationships with the applicable manufacturers and GPOs are correctly reported prior to release of the data to the public.
CMS will open registration for physicians and teaching hospitals through the CMS Enterprise Portal following the completion of Phase 2 reporting for manufacturers and GPOs. This registration process and ability to review/correct submitted data is anticipated to open no later than August 1, 2014.
If you want to be alerted when the registration process opens and/or receive other updates regarding Open Payments, subscribe to the CMS Open Payments listserve.
Joyce Harris-Hennessy is a partner in Thompson Coburn's Health Law Practice Group. She can be reached at (314) 552-6165 or jhennessy@thompsoncoburn.com.