decisionhealth Newsletters, Part B News - 2013 Issue 6 (June)
Use CMS’ 45-day period to dispute inaccuracies for open payments website
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Article Overview
This article covers the CMS Sunshine Act/Open Payments reporting timeline and the physician review period for disputing inaccurate payment data before it appears on the public website. It is relevant to physicians, teaching hospitals, compliance staff, and practice administrators who need to understand reporting, registration, recordkeeping, and dispute handling under the CMS program. The article also summarizes the roles of manufacturers, GPOs, physician-owned distributorships, and CMS in the submission, review, correction, and posting process.
Why This Topic Matters
Accurate Open Payments data affects public transparency and can impact how patients and others view provider relationships with industry. Practices that prepare in advance are better positioned to identify errors, document discrepancies, and participate in the CMS review window.
Article Sections
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Sunshine Act
Introduces the Open Payments context and the reporting timeline that frames the rest of the article. It explains the general scope of industry payment reporting and public disclosure.
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How the disputes work
Outlines the CMS reporting and review sequence, including the period when reported data becomes available for physician review and the follow-up correction phase. It describes the organizations involved in submitting and revising the information.
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How to address incorrect data
Summarizes broad practice steps for preparing to review reported information and raise concerns about inaccuracies. It covers recordkeeping, voluntary registration, advance review opportunities, and escalating unresolved issues.
What You Will Learn
- The overall CMS Open Payments timeline and review process
- How practices can prepare to compare reported data with their own records
- What broad steps are involved in disputing inaccurate reported information
- Who participates in the reporting, review, and correction process
- Why voluntary registration and internal documentation can be helpful
Who Should Read This
- Physicians
- Teaching hospitals
- Medical practice administrators
- Compliance staff
- Billing and reimbursement staff
- Health care attorneys
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