Conflict of Interest
Open Payments Registration
The 45 day review and dispute period for 2015 data in the Open Payments (Sunshine Act) system will open on April 1st and close May 15th. During this period of time, physicians about whom a manufacturer has reported one or more payments will be able to register and view the reported payments in advance of the June 30 public release of the information. If any of the reported payments appear to be incorrect, physicians have until May 15th to resolve the dispute directly with the manufacturer, who can submit revised information to CMS. All resolutions must be completed by May 30th. You can go to https://www.cms.gov/openpayments/ for the most current information, instructions, and FAQs. The review process is voluntary, but to participate in the process and review and correct the data, physicians will need to register in both the CMS Enterprise Identity Management System (EIDM) and the Open Payments system.
CMS notification and instructions (click here for pdf)
What do you need to do to see the reported payments?
Physicians must register both with the CMS Enterprise Portal and then with Open Payments. A couple of key points:
- You do not need to wait for April 1st to register in the system. CMS encourages physicians to register now, so that you can go directly to the Open Payments review and dispute page April 1.
- If you have previously registered in these systems but have not logged in within 180 days, the account will be inactivated and you should call the support desk to reinstate the account.
- Here is the contact information for the Help Desk: For live assistance, call Help Desk Support at 1-855-326-8366, Monday through Friday, from 8:30 a.m. to 7:30 p.m. (EST), excluding Federal holidays, or send an email to Openpayments@cms.hhs.gov
What should you do if a reported payment is inaccurate or should be disputed?
- You must note the dispute directly in the Open Payments system, which will alert the manufacturer of the dispute.
- New this year: CMS has revised the dispute display to show contact information for the person at the company who is responsible for resolving the disputed payment. When disputing a payment, or if you have questions about a reported payment you should note this contact information.
- CMS strongly encourages individuals to include their own contact information in the comments with the disputes to facilitate rapid resolution of the dispute.