Open Payments/Sunshine Act Resources
The Open Payments system is a website created by CMS to publish data from pharmaceutical, biological, and medical device manufacturers (“Applicable Manufacturers”) about payments and other transfers of value to physicians, dentists, and teaching hospitals.
Providers can search their 2013 and 2014 data here: https://openpaymentsdata.cms.gov/
Review and Correct Your Payment Data
Providers have the option to view and dispute payment data submitted by Applicable Manufacturers. Even if you do not believe you received payments, you are advised to register and verify that your information is accurately represented in the Open Payments system.
- May 15, 2016 is the deadline to submit corrections to payment data that will be posted on Open Payments in June of 2016. Providers can submit disputes after May 15th, but information posted on the Open Payments website will not be updated until the next “resolution period,” as determined by CMS.
- The opportunity to dispute payment data expires at the end of the calendar year when the record is published (e.g., 2015 data published in June 2016 can be disputed through December 2016).
Live Help Desk: Email questions to the Help Desk at firstname.lastname@example.org or call 1-855-326-8366, Monday through Friday, from 8:30 a.m. to 7:30 p.m. (ET).
- Inactive accounts: If you previously registered but your account has been inactive for more than 60 days, you will need to login to the CMS Secure Portal, enter your user ID and correctly answer all challenge questions. If your account has been inactive for more than 180 days, your EIDM account will be deactivated, and you should contact the Live Help Desk (see above).
The two-step registration process includes a brief waiting period between completing registration and receiving access to your payment data. CMS states that the registration process takes approximately 30 minutes.
You will need the following information to register:
- All active state license number(s) (SLN)
- National Provider Identifier (NPI) number (if you have one)
- Drug Enforcement Agency (DEA) number (if you have one)
- If you do not enter an NPI number, you will likely have to enter a specialty code obtained from the Physician Taxonomy Codes.
- If you are not a clinical provider, but receive payments from an Applicable Manufacturer (e.g., a non-physician Principal Investigator), contact the Help Desk for login assistance.
Note regarding delegation: It is unlikely that anyone else will be able to correctly answer the identity verification questions on your behalf. Once you establish an account, you can designate one authorized representative.
Two registration steps are required:
1. Identity verification: This is done in the CMS Enterprise Identity Data Management (EIDM) system, at https://portal.cms.gov (select “New User Registration”).
a. Refer to the EIDM Quick Reference Guide if needed: https://www.cms.gov/OpenPayments/Downloads/Quick-Reference-Guide-Enterprise-Identity-Management-System-Registration.pdf
b. Ensure the name entered for EIDM registration matches exactly with the way your name is listed in the National Plan and Provider Enumeration System (NPPES).
c. You will be asked questions similar to what you would see on a credit report to verify your identity such as questions about what high school you graduated from, or who services your mortgage.
d. You will receive an email confirming vetting success or failure. If unsuccessful, contact the Help Desk.
2. Register in the Open Payments system:
a. Log in to the CMS Enterprise Portal at https://portal.cms.govusing your EIDM credentials, navigate to the Open Payments home page, and select “Create My Profile.”
b. Most users will select “Physician” as the profile type.
c. You will need additional professional information, such as your business email, phone, practice name, and address.
d. The automatic vetting process normally takes less than 24 hours, though it could take longer depending upon the completeness of the information provided by the user and the number of physicians undergoing vetting at the same time.
Reviewing and Disputing Records
- After reviewing your 2015 payment information, go to the “Review and Dispute” tab and enter your name. You may take the following actions on a record:
- Affirm the record (you are not required to take this step, as unaffirmed records will still be published; affirmed records can be subsequently disputed)
- Initiate a dispute (reporting entity will receive an email notification of the dispute)
- Withdraw a dispute
- Dispute resolution takes place outside the Open Payments system; CMS does not mediate disputes between the provider and the Applicable Manufacturer.
- New this year: Applicable manufacturers who report data are now required to provide contact information to facilitate the dispute resolution process.
- Contact information can be found on the “Record Detail” page; select “Record ID”
CMS Open Payments User Guide
For complete information about the Open Payments system, including screen shots of the website and detailed user instructions, see https://www.cms.gov/OpenPayments/Downloads/Open-Payments-User-Guide.pdf (Part IV: Physicians and Teaching Hospitals, begins on page 223 of the PDF)
Page date: 05-03-16