The CMS has posted new resources to its “Open Payments” website to clarify its recently announced two-stage approach to registration and data submission. These resources include:
- Step-by-step instructions for completing new user registration with the CMS Enterprise Portal,
- A sample template to be used for Phase 1 aggregate data submission, and
- New frequently asked questions (FAQs) on the CMS FAQ website to address recent questions about the phased approach to registration and data submission.
CMS has promised to provide specific information about the dates for Phase 2 registration and data submission, as well as when registration and review/correction will open for physicians and teaching hospitals (which CMS says will be no later than August 1, 2014). In the meantime, CMS held today a webinar about Phase 1 submission, which it plans to post online here.
During today’s webinar, CMS addressed questions and clarified key points, such as that:
- the aggregate data submitted in Phase 1 does not need to be the same as the total of the detailed payments submitted in Phase 2 (CMS acknowledged that manufacturers may not have yet completed tallying reportable payments), and
- consolidated reports are not accepted in Phase 1; instead, each entity must register and report separately. CMS also stated—consistent with past Sunshine Act Task Force analysis—that any payments to physicians practicing abroad, if they have an active US state license, are reportable.
CMS has also reiterated, as previously announced, that it will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission.