CMS’ Open Payments Advance Revenue Cycle Transparency
By - Physicians and teaching hospitals across the healthcare spectrum will be buried in a numbers game come April 6, 2015 when The Centers for Medicare & Medicaid Services’ (CMS’) period of payment review for physicians begins.
Open Payments is a national disclosure program generated from the Affordable Care Act (ACA), “which requires applicable manufacturers of drugs, devices, biologicals, or medical supplies covered under Medicare or a State plan under Medicaid or [Children’s Health Insurance Program] CHIP to report annually to the Secretary certain payments or other transfers of value to physicians and teaching hospitals,” reports CMS and the Department of Health and Human Services (HHS).
In direct connection to this program, The Physician Payments Sunshine Act, a facet of both the Patient Protection and ACA, formerly calls for increased transparency regarding financial arrangements between drug and device manufacturers and physicians, confirms the AAFP (American Academy of Family Physicians).
To actively instill such initiatives, CMS subsequently instigated the Open Payments program. There are several significant objectives of the Open Payments program. One goal is to advance public awareness of the financial relationships existing between the healthcare industry (i.e. pharmaceutical companies) and physicians or teaching hospitals. Payments or value transfers for a variety of purposes, including research, consulting, travel, or gifts, are collected and reported to physicians and teaching hospitals via the healthcare industry. CMS subsequently collects this data on a yearly basis and makes it virtually available to the public.
Examples of the types of payments drug and medical device manufacturers must report to physicians and teaching hospitals include speaker fees, vacations, food and beverage, travel and lodging, charitable contributions, or royalties and licenses.
CMS published information last year about almost four and a half million payments valued at $3.7 billion for the last five months of 2013. Such transparency is vital, says CMS, for stakeholders to richly analyze, monitor, and use the information accordingly.
2014 payments reported to the Open Payments program may be reviewed and disputed regarding alleged inaccuracies by physicians and teaching hospitals within a forty-five day window beginning April 6, reports CMS.
Physicians and teaching hospitals may register for both the Open Payments system and the CMS Enterprise Portal, review transactions, dispute inaccurate data, and provide rationale for why a reported payment or other transfer of value is deemed inaccurate. Although both parties may initiate disputes after the window of time has formerly closed, resolutions will not be publicly displayed until commencement of the next reporting cycle.
Following the forty-five day window, manufacturers and group purchasing organizations (GPOs) must resolve and submit corrections within a fifteen day period before the data is publically released. Unresolved disputed data within this period will be marked as disputed and publicly reported at the end of June.
According to CMS, the aforementioned payment methods often spark conflicts of interest. As CMS confirms within its Open Payments Methodology Overview and Data Dictionary, “Financial ties between the health care industry and health care providers do not necessarily signal wrongdoing.”
CMS adds it actively urges healthcare providers discuss such relationships with their beneficiaries. Communication is key to avoid preventable hiccups along the way.
“Open Payments doesn’t identify which financial relationships are beneficial or which may cause conflicts of interest,” CMS adds. “Instead, the program is designed to increase public awareness about these relationships and discourage payments and other transfers of value that might have inappropriate influence on research, education, standard setting, and most importantly, clinical decision making.”
CMS recommends healthcare providers and organizations keep track of their financial interactions and review information submitted by other manufacturers prior to the information being posted to the public. It also emphasizes learning what to do if there is a disagreement with submitted information.
Getting even with odd numbers is a primary objective the healthcare industry should actively focus and openly communicate about on to ensure future revenue cycle success.
