Saturday, April 1, 2023

Open Payments Pre-Publication Review & Dispute Opens Today

Centers for Medicare & Medicaid Services

Open Payments Pre-Publication Review and Dispute Open Today!

Pre-publication review and dispute for the Program Year 2022 Open Payments data is available beginning today, April 1, 2023 through May 15, 2023.

Open Payments is a national disclosure program that promotes a transparent and accountable health care system. Open Payments houses a publicly accessible database of payments that reporting entities, including drug and medical device companies, make to certain health care providers, which are referred to as covered recipients .

As a reminder, the definition of a covered recipient includes the following health care providers:

  • Physicians
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists & anesthesiologist assistants
  • Certified nurse-midwives
  • Teaching Hospitals 

From February 1, 2023 through March 31, 2023 the reporting entities submitted their 2022 data to the Centers for Medicare & Medicaid Services (CMS). CMS will publish the Open Payments Program Year 2022 data and updates to the previous program years' data in June 2023.

Now is your opportunity to review the data before it is published. Covered recipient review of the data is voluntary, but strongly encouraged as this ensures the accuracy of the data.

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Pre-Publication Review & Dispute Actions

The Pre-publication review and dispute period provides covered recipients the opportunity to review data attributed to them prior to the data publication. During this time covered recipients may review and affirm that the data is correct or if necessary they may dispute data that they believe to be incorrect or inaccurate in any way. Please note that simply reviewing the data does not indicate if it is correct. In order to note that you agree with the data attributed to you, you should take the action of affirming.

The Program Year 2022 Pre-publication Review and Dispute period is from April 1, 2023 through May 15, 2023.

Please keep in mind the following reminders:

  • Disputes must be initiated by May 15, 2023 in order to be reflected in the June 2023 data publication. For more information on review and dispute timing and publication, refer to the Review and Dispute Timing and Data Publication Quick Reference Guide.

  • CMS does not meditate or facilitate disputes. Covered recipients should work directly with reporting entities to resolve disputes. Remember to provide your most up to date contact information when initiating a dispute; this is beneficial in case the reporting entity needs to contact you directly to reach a dispute resolution.

  • Registration in the Open Payments system is required in order to participate in review and dispute activities.

Detailed information about the Review and Dispute process is available in the Review and Dispute Tutorial for Covered Recipients, located on the Resources for Covered Recipients page.

Registration Reminder:
In order to participate in the Pre-Publication Review and Dispute period, covered recipients must be registered in the CMS Identity Management System (IDM) and have access to the Open Payments System.

Registration is a two-step process:

  1. Register self in IDM at the CMS Enterprise Portal and request access to the Open Payments System
  2. Register as a covered recipient in the Open Payments System

Registration details are available on the Covered Recipient Registration Page. The Open Payments team recently released two registration videos. These videos provide information for covered recipients about the registration process, including a step-by-step tutorial of the registration process.

There are two versions of the registration video, one for physician and non-physician practitioner (NPP) covered recipients and one for teaching hospital covered recipients. The videos are available at:

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Open Payments Resources

We are pleased to share a variety of resources about the program. There is an Open Payments Overview Video which provides details about what the program is, who is involved, and how the program operates. There is also a Natures of Payment video that highlights what the Open Payments Natures of Payments are and how they are reflected in the data. 

As mentioned above, there are two new registration video tutorials. Along with the tutorials are quick start guides that provide information for what you should have on hand when you start the registration process. These items are available on the  Covered Recipient Registration Page

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Questions - Contact the Help Desk

Need help or have questions? Contact the Open Payments Help Desk at openpayments@cms.hhs.gov or call 1-855-326-8366 (TTY Line: 1-844-649-2766). The Help Desk is available Monday through Friday, from 8:30 a.m. to 7:30 p.m. (ET), excluding Federal holidays.

The Help Desk refers media inquiries to CMS' Press Office for response.

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Creating Public Transparency of Industry-Provider Financial Relationships.


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