CMS hosted a Q&A conference call on April 12th, 2017 to discuss the open payments data correction and publication process. According to CMS, there are no major changes from 2016.
As before, dispute resolution takes place outside of the Open Payments system and CMS does not mediate disputes. Physicians, teaching hospitals, and principal investigators should work with the reporting entity to resolve any disputed record(s).
What does this mean for Polaris’ clients? It means there are no changes to the procedures you have been following, and to continue reporting as you have been. For your convenience, we have outlined a high-level summary of the process below:
Reporting entities must submit all data by March 31st, 2017. Physicians, teaching hospitals, and principal investigators have a 45 day review and dispute period starting from April 1st-May 15th to review, dispute, and work with the reporting entity to resolve any disputes. Reporting entities then have an additional 15 day correction period until May 30th to make any final corrections and resolve any active disputes. The data is published in the initial publication, which is released on June 30th, 2017.
Although physicians, teaching hospitals, and principal investigators can initiate disputes through the end of 2017 for all records submitted by March 31st, 2017, disputes initiated by or before May 15th only affects how the dispute is displayed in the initial and refresh publication.
- Any disputes initiated by or before May 15th and resolved by May 30th will not be published as disputed in any publications.
- Any disputes initiated by or before May 15th and not resolved by May 30th will be published as disputed in the initial publication and refresh publication, unless the dispute is resolved before the end of 2017.
- Any disputes initiated after May 15th and resolved before May 30th will not be published as disputed in the initial or refresh publication.
- Any disputes initiated after May 15th and not resolved before the year end will not be published as disputed in the initial publication, but will be published as disputed in the refresh publication.
- Any records deleted by May 30th, 2017 will be deleted and not published.
- Any records with a new covered recipient identifier will be considered a new record and will have to be resubmitted. These records will be published in 2018’s initial data publication.