The Centers for Medicare & Medicaid Services recently published the 2018 Open Payments data. Open Payments is a disclosure program designed to promote transparency by making available to the public the financial relationships between manufacturers and group purchasing organizations (GPOs) and physicians and teaching hospitals. The principle purpose is to increase transparency and promote fair and smart spending in the healthcare sector.
In the 2018 report, which includes transactions that took place between Jan. 1 and Dec. 31, applicable organizations reported $9.35 billion in publishable payments, ownership, and investment interests to healthcare professionals (HCPs) and healthcare organizations (HCOs). This accounts for 11.40 million records attributable to 627,392 physicians and 1,180 teaching hospitals, according to CMS.
For reporting purposes, the payments are broken down into three categories:
- Ownership and investment
General payments accounted for $3 billion, research payments for $4.93 billion, and ownership or investment for $1.42 billion, according to CMS. The latter includes ownership and investment by both physicians and their immediate family members.
By early 2020, CMS will publish a refresh of the 2018 data to reflect any updates. The reporting requirement has multiple purposes, according to CMS. Among the reasons are to help identify relationships that can lead to the development of new technologies or wasteful spending, understanding the extent of certain financial relationships, and preventing inappropriate influence on research, education, and clinical decision making.
Patients can use the information to learn about the relationships their doctors have with various life sciences organizations, including the companies that make the devices and medications for which they have been prescribed, and ask their providers relevant questions. Doctors, of course, can ensure the data is accurate and also prepare for questions from the public.
For life sciences organizations, this data can be vital. It provides an overview of what’s happening internally but also throughout the industry. Having a plan to successfully analyze the data to recognize best practices, weed out bad actors, and identify better strategy can be key to gaining a competitive edge.
Most importantly, life sciences organizations must recognize the publishing of CMS data as an opportunity to focus their compliance strategy. After all, failure to comply with Open Payments can result in civil monetary penalties of up to $1 million. A violation is incurred if an organization “fails to report information in a timely, accurate, or complete manner,” according to CMS.
Organizations must keep record of their data for up to five years and may be subject to an audit by CMS at any time. As a result, keeping up to date on transparency reporting requirements and following through on collecting and sharing the appropriate data is key to minimizing risk. This is further proof that making compliance a priority and investing in technology that can make transparency reporting more efficient and practical is a necessity.