A blog by attorneys for anyone interested in or affected by The Sunshine Act.

Physician and Teaching Hospital Registration Re-Opens for Review and Dispute

August 15, 2014
Ruselle W. Robinson

CMS announced today that the Sunshine Act/Open Payments system is back online.  Registered physicians and teaching hospitals once again can review (and dispute, if necessary) payment and physician ownership data reported about them by applicable manufacturers and applicable group purchasing organizations.

CMS shut down the Open Payments system earlier this month to investigate what it is now calling a “data integrity issue”.  Other sources reported that at least one manufacturer had confused two physicians of the same name and reported payments that named the wrong physician (See my post dated August 7, 2014).

Because of the shutdown, CMS pushed back dates for the review and dispute period, as well as for the correction period.  However, CMS did not change the September 30, 2014 date for posting 2013 payment and physician ownership data on the Open Payments website.  The revised dates are as follows:

Old Dates 

End of Review and Dispute                 August 27, 2014

End of Correction Period                    September 11, 2014

Posting of Data on Website                September 30, 2014

New Dates

End of Review and Dispute                September 8, 1014

End of Correction Period                    September 23, 2014

Posting of Data on Website                September 30, 2014

The review and dispute period will run a total of 45 days (not including the days of interruption), and the correction period will run 15 days.

CMS issued the following statement about the shutdown:

CMS took swift action to close the system and fully investigate issues which indicated possible data matching errors within the Open Payments system. Applicable manufacturers and group purchasing organizations (GPOs) submitted intermingled data, such as the wrong state license number or national provider identifier (NPI), for physicians with the same last and first names. This erroneously linked physician data in the Open Payments system. After careful review, CMS implemented a system modification that included more enhanced algorithms and validation checks to resolve the issues, and verified that the physician identifiers used by the applicable manufacturer or GPO are accurate, and that all payment records are attributed to a single physician. Incorrect payment transactions have been removed from the current review and dispute process and this data will not be published this year.

Data accuracy is critical to the success of this transparency program, and CMS is committed to ensuring the integrity of data made available to the public.

Here is the link to the CMS Review and Dispute registration page:  http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Physicians.html

The revised timeline leaves CMS very little room to address new problems if they arise.  I will continue to report on developments as “review, dispute and correction” moves forward.


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