Per the notice below, the Centers for Medicare and Medicaid Services (CMS) has issued an update on the Open Payments program review and dispute process.
Pre-Publication Review and Dispute
Open Payments Pre-Publication Review and Dispute is available through May 15, 2023.
Open Payments is a national disclosure program that promotes a transparent and accountable health care system. Open Payments houses a publicly accessible database of payments that reporting entities, including drug and medical device companies, make to certain health care providers, which are referred to as covered recipients. As a reminder, the definition of a covered recipient includes the following health care providers:
- Physicians
- Dentists
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists & anesthesiologist assistants
- Certified nurse-midwives
- Teaching Hospitals
From February 1, 2023, through March 31, 2023, the reporting entities submitted their 2022 data to the Centers for Medicare and Medicaid Services (CMS). CMS will publish the Open Payments Program Year 2022 data and updates to the previous program years’ data in June 2023. Now is your opportunity to review the data before it is published. Covered recipient review of the data is voluntary, but strongly encouraged as this ensures the accuracy of the data. Check out our new Review & Dispute Quick Start Guide for helpful tips on the review and dispute process!
The Pre-publication review and dispute period provides covered recipients the opportunity to review data attributed to them prior to the data publication. During this time covered recipients may review and affirm that the data is correct or if necessary they may dispute data that they believe to be incorrect or inaccurate in any way. Please note that simply reviewing the data does not indicate if it is correct. In order to note that you agree with the data attributed to you, you should take the action of affirming.
The Program Year 2022 Pre-publication Review and Dispute period is from April 1, 2023, through May 15, 2023.
Please keep in mind the following reminders:
- Disputes must be initiated by May 15, 2023, in order to be reflected in the June 2023 data publication. For more information on review and dispute timing and publication, refer to the Review and Dispute Timing and Data Publication Quick Reference Guide.
- CMS does not meditate or facilitate disputes. Covered recipients should work directly with reporting entities to resolve disputes. Remember to provide your most up to date contact information when initiating a dispute; this is beneficial in case the reporting entity needs to contact you directly to reach a dispute resolution.
- Registration in the Open Payments system is required in order to participate in review and dispute activities.
Detailed information about the Review and Dispute process is available in the Review and Dispute Tutorial for Covered Recipients, located on the Resources for Covered Recipients page.
We are pleased to share a variety of resources about the program. There is an Open Payments Overview Video which provides details about what the program is, who is involved, and how the program operates. There is also a Natures of Payment video that highlights what the Open Payments Natures of Payments are and how they are reflected in the data. As mentioned above, there are two new registration video tutorials. Along with the tutorials are quick start guides that provide information for what you should have on hand when you start the registration process. These items are available on the Covered Recipient Registration Page.
Need help or have questions? Contact the Open Payments Help Desk at openpayments@cms.hhs.gov or call 1-855-326-8366 (TTY Line: 1-844-649-2766). The Help Desk is available Monday through Friday, from 8:30 a.m. to 7:30 p.m. (ET), excluding Federal holidays. The Help Desk refers media inquiries to the CMS Press Office for response.