“Where are you in the Aggregate Spend Data Registration and Submission Process”?
CMS Addresses Key Questions In Webinar Yesterday
CMS provided a step-by- step review of the EIDM and Open Payments registration process (described here) for Phase 1 aggregate spend data in a webinar yesterday. While no changes were announced in the process, some important corrections and clarifications were addressed around the following questions:
Q: What are some important things to take note of in the EIDM registration process?
A: Previously, CMS’ instruction around Phase 1 aggregate spend submission noted that the EIDM User ID should be in the following format: ##-######-###. CMS clarified that this instruction is erroneous, as the authorized official is permitted to choose their own User ID, which need not match this format. Additionally, the authorized official’s Social Security Number is optional for EIDM registration (but required for Open Payments registration). Finally, the authorized official should be entering his/her residential address and not his/her business office address, unless the residential address is outside of the United States. In the latter situation, the U.S. business office address could be used. This may, however, cause a delay in verification.
Q: When can roles be delegated in the data submission process?
A: Delegation of roles occurs in Phase 2 only. While the authorized official does not delegate any roles during Phase 1 registration, any individual may submit the e-mail containing the Phase 1 data submission.
Q: What template should be followed for submitting data?
A: Previous CMS instruction on the aggregate spend data template listed the required fields in an order which did not correspond to the field order in the sample template. CMS clarified that the submission should follow the field order in the sample template.
Q: When can reporting be consolidated?
A: No consolidated manufacturer reporting can occur in Phase I. Further, a paragraph 2 Applicable Manufacturer must register and submit aggregate data to CMS separately from the paragraph 1 Applicable Manufacturer.
Q: When should the Assumptions document be submitted?
A: The Assumptions Document should be submitted only in Phase 2.
Q: What if there are discrepancies between Phase 1 and Phase 2 data submissions?
A: CMS stated that it does not expect that an Applicable Manufacturer’s spend totals between Phase 1 and Phase 2 will be exactly the same.
Polaris will provide further updates and perspectives as the registration and submission process continues.
For further clarification or additional details on the CMS updates or to discuss specifically the impact of these CMS updates for your company, please contact Ben Carmel or Dakota Gallivan or email us at Polaris Aggregate Spend.