Update 3/9/2017: The review and dispute period for the 2016 Open Payments dataset is targeted to start in April 2017, following the close of data submission (the Program Year 2016 data submission window begins on February 1, 2017 and ends on March 31, 2017). Physicians and teaching hospitals have 45 days to review and dispute records attributed to them.
Please remember to disclose and update external interests through COI Smart and submit an update within 30 days of any significant financial interests. For additional information, visit feinsteininstitute.org/coi
Open Payments Physician Registration
We highly recommend that physicians regularly review their information on Open Payments and dispute any reported data discrepancies in a timely fashion. Disputes must be made directly with the company providing information to CMS. Publicly available data posted on CMS.gov are reviewed annually by Northwell Health compliance offices against information submitted on External Interest Disclosure forms.
Physicians must register in the CMS’s Enterprise Identity Management system (EIDM*) and the Open Payments system in order to view, review, and/or dispute data submitted about them. Note that physicians and teaching hospitals are not required to register but are encouraged to do so in order to view payment information reported about them.
- Open Payments system Quick Reference Guide Physician Registration (Updated January 2017)
- The quick reference guide on the EIDM system can be found here.
* The CMS Enterprise Portal locks accounts if there is no activity for 60 days or more and deactivates accounts if there is no activity for 180 days or more. To unlock an account, go to the CMS Enterprise Portal, enter your user ID, and correctly answer all challenge questions; you’ll then be prompted to enter a new password. To reinstate an account, contact the Open Payments Help Desk.
**Physicians and teaching hospitals who registered last year do not need to register again in the CMS Enterprise Portal or the Open Payments system.
Open Payments Registration Quick Links.
- CMS Enterprise Portal
- Open Payments System Quick Reference Guide Correcting and Resolving Disputes
- FAQs on Open Payments
Review Available Educational Materials
There are a number of useful educational materials available to help physicians and teaching hospitals learn more about the Open Payments registration process. These materials are available on the Resources page of the Open Payments website. For a holistic view of the Open Payments program, you may want to begin by reviewing the 2015 Open Payments Program Overview and Enhancements – PDF .
Questions—Contact Live CMS Help Desk
Submit questions to the CMS Help Desk via email at firstname.lastname@example.org or by calling 1-855-326-8366, Monday through Friday, from 8:30 a.m. to 7:30 p.m. (EST), excluding Federal holidays. Peak Help Desk call time is between 12:00 p.m. and 3:00 p.m. (EST).
PREP Course #5: All About the Physician Sunshine Act/Open Payments
PREP Course #9: Interactions with Industry Do’s and Don’ts
The Affordable Care Act (ACA), through several provisions known as the Physician Payment Sunshine Act, requires applicable manufacturers of drugs, devices, biologicals, or medical supplies covered under Medicare, Medicaid, or CHIP to report annually in electronic format to the Center for Medicare & Medicaid Services (CMS) certain payments or other transfers of value to physicians and teaching hospitals. Applicable manufacturers and applicable group purchasing organizations (GPOs) are subject to civil monetary penalties (CMPs) if they fail to comply with the reporting requirements of the statute. CMS will collect the data annually, aggregate it, and publish it on a public website. CMS must then submit annual reports to the Congress and each State summarizing the data applicable manufacturers have reported.