For the first time, yesterday, CMS, as part of Open Payments transparency, published the detailed report of payments from applicable manufacturers and GPOs to physicians and teaching hospitals. This data, comprised of 4.4 million payments/transfers of value, valued at approximately $3.5 billion, represents payments and transfers of value made between August 1 and December 31, 2013. A large amount of submitted data, however, has not been published in full detail either due to unresolved disputes between manufacturers and recipients or because of yet to be corrected data.
Of the general payments data which has been fully identified and published, Polaris has been able to glean the following:
In leveraging this data, companies should consider whether their spend stands significantly apart from the industry, with respect to: 1) average spend in any given category and 2) the categories in which their spend falls. High or significant spend that falls into such areas should be a focus of a company’s investigations and also their auditing and monitoring plan.