Regulatory update: CMS Open Payments expanded to five new provider types

Provider review and refute period: April 1 - May 15

CMS Open Payments is a federal program that provides transparency and increases public awareness of financial relationships between the healthcare industry and certain healthcare providers and teaching hospitals. The program does this by collecting and making public any payments or transfers of value from drug and device manufacturers to certain healthcare providers or teaching hospitals. 

Per Open Payments, all transfers of value from an industry representative to certain healthcare providers or teaching hospitals valued at or above $10, or aggregate of $100 per year, are reported. Transfers of value may include food and beverage, entertainment, charitable contributions, speaking fees, royalties or licenses, grants, consulting fees, honoraria, travel and lodging, education, research and more. The nature and purpose of the amount are also recorded and disclosed.

The Open Payments program has expanded to include the five new provider types:

• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists and anesthesiologist assistants
• Certified nurse-midwives

For healthcare providers, the CMS review and dispute period is April 1 - May 15, 2022. Starting April 1, providers can review their 2021 data posted by drug and device manufacturers. This review and dispute period allows physicians and other covered recipients to dispute any inaccurate or incomplete data before it is published to the public on June 30, 2022. Each YNHHS provider is accountable for reviewing their 2021 data and disputing any inaccurate information during CMS’ review and dispute period. Yale New Haven Health’s Office of Privacy and Corporate Compliance (OPCC)  will be reviewing applicable CMS Open Payments data once released on June 30 and may contact providers regarding their Open Payments data if it is not aligned with their most recent Conflict of Interest disclosure survey responses. 

Providers should ensure all interactions with drug and device manufacturers comply with the Interactions with Vendors policy.

For your convenience, additional guidance material is available from the OPCC (intranet).

If you have questions or concerns, contact the OPCC: 203-688-8416 or [email protected].