Aggregate Spend Reporting Update: Open Payments Registration

02.20.14 | By Ben Carmel

After completing registrations with some clients, we have noticed some patterns, and naturally additional questions have been raised.

The overall process is partially in line with our expectations from previous CMS communications, but not completely.

Some key considerations from registration:

1. As expected, companies will first need to register the individual “authorized official” in the CMS Enterprise Portal

  • Standard personal information is requested, along with almost a “credit check”  verification of that individual
  • The individual will choose his/her user ID during this process.
  • This takes about 5 minutes total

2. Once this is complete, the authorized official will need to log out and log back in (after waiting about 5 minutes) to register that individual specifically for Open Payments

  • This is really just a couple of clicks and takes a minute or so

3. After Open Payments registration you are taken to a final individual submission screen

  • This instructs users that an email will need to be sent by the registrant with submitted data by March 31st
  • Click on the “Registration” option to access the data submission instructions, please contact us if you would like the file
  • The data submission sample, a pipe delimited CSV that will need to be populated, please contact us if you would like the file

4. Fields for the March 31st submission are:

  • Authorized official’s EIDM user ID
  • Registering entity legal name
  • Registering entity’s doing business as name
  • Registering entity business type
  • Website address/uniform resource locator (URL) of parent company
  • Registering entity business address line 1
  • Registering entity business address line 2
  • Registering entity city
  • Registering entity state
  • Registering entity zip code
  • Registering entity country
  • Registering entity province
  • Registering entity postal code
  • Registering entity business telephone number
  • Research payments aggregate data:
    • Total aggregate amount (in dollars and cents)
    • Total number of payments or other transfers of value made
    • Total number of covered recipients (unique/non-duplicate)
  • General payments aggregate data:
    • Total aggregate amount (in dollars and cents)
    • Total number of payments or other transfers of value made
    • Total number of covered recipients (unique/non-duplicate)
  • Ownership or investment interests aggregate data:
    • Total number of instances of physician ownership or investment interests

What strikes us as missing, was the area to register the company. After being armed with DUNS numbers and so on, this section was not part of the initial registration.  Also, it does not appear that other individuals can be registered at this time.  Logically, this is tied to the overall company registration. Our guess is that CMS will first fully vet the authorized official (previous CMS webinar has said this could take up to 2 weeks or so) and that the DUNS numbers, etc. would be completed in Phase 2 where the authorized official is to “complete Open Payments registration for the entity”.

As a reminder, CMS is conducting a registration and data submission webinar on Tuesday, February 25, from 1-2pm EST.  Polaris will be attending and can provide full and detailed summaries of the call, so please contact us if you would like receive this information. If you would like to have us submit questions for Tuesday’s webinar please send them to the contact information below.

Stay tuned for further details coming out of the webinar and as the registration process continues.

***

For clarification, additional detail or to discuss specifically for your company and solution please feel free to contact Ben Carmel or Dakota Gallivan or email us at Polaris Agg Spend