We are only a few months away from the August 1st deadline to track payments made to healthcare practitioners and teaching hospitals. As the date nears CMS has recently released informative fact sheets and a PDF file of covered teaching hospitals.
These fact sheets can be found here and are written for Manufacturers, Physicians, Teaching Hospitals and Group Purchasing Organizations (GPO’s). These fact sheets can be utilized as an awareness tool for your employees, physician partners and distributors.
A research payment, fellowship support or space rental fees made to a facility by a manufacturer will also need to be tracked. Utilization and integration of the PDF dataset of teaching hospitals into your physician transparency documentation processes is a necessity. The CMS provided list identifies the recipients for whom payments will need to be tracked and the facility identification data which must be included in your submitted report.
CMS recently scheduled an Open Door forum on this topic. Additional information and registration information can be found on the CMS website.
In reviewing the CMS OPEN PAYMENTS website it is also interesting to note that they have a specific section on audits and penalties. It is very clear that CMS will conduct audits and any penalties “collected will be used by CMS to implement OPEN PAYMENTS”. CMS has a clear incentive and need to impose penalties as this will fund the ongoing operations of the program.
An applicable manufacturer should ensure that they are currently collecting all the required data in an easily reportable format and can provide supporting records related to the transfers of value in the event of an audit.
To assist our clients MCRA has developed a low cost, web based, secure software solution that can not only efficiently aggregate all physician payment data but also manages the entire compliance program.
Key features include:
- Capture, Track and Report all Aggregate Spend
- Manage HCP Relationships and Contract
- Contains National Salary Data to Compute a FMV Hourly Rate
- Includes a 24 / 7 Compliance Hotline / Website
- Complete management of all elements of an effective compliance program, including tracking all policies and procedures, issues and other required elements of a compliance program.
Please contact me to schedule a brief complimentary discussion and demo surrounding this new service offering from MCRA. I can be reached at 860-904-4451 or by email at firstname.lastname@example.org.