As we noted last week, CMS released two mobile apps for tracking reportable payments: one for physicians and one for applicable manufacturers and applicable GPOs. Both are available for download now for iOS (Apple™) and Android™ mobile phones. New FAQs from CMS provide additional visibility into how CMS envisions physicians and industry using these mobile apps for tracking and reviewing OPEN PAYMENTS Data.
Highlights of the FAQs include:
- The apps will allow users to collect personal information and serve as a storage depository only. The apps will not interact with CMS systems or CMS contractors. The apps cannot be used as a tool to submit official data to CMS regarding financial payments and other transfers of value;
- The data stored using the app is owned by the users. All data entered into the apps is stored locally on the users’ devices, and users are recommended to backup data regularly;
- CMS will not validate the accuracy of data stored in the apps, nor will CMS be responsible for protecting data stored in the apps;
- The apps’ security features include password protection, security questions, a “forgot password” feature, an automatic erase feature after 11 incorrect login attempts, and automatic logoff when a user leaves the app;
- Use of the apps is voluntary and users do not need to register with CMS to use the apps;
- All types of physicians may use the physician app, including doctors of medicine and osteopathy, dentists, podiatrists, optometrists, and chiropractors;
- The app for physicians allows physicians to store their own personal profile information such as name, address, contact information, National Provider Identifier (NPI), state medical licensure number, and other relevant information;
- The apps allow information to be transferred between the apps for physicians and industry. For example, physicians can transfer to industry representatives: (i) physician profile contact information; and (ii) the details of events surrounding payments or transfers of value. Transfers may be made at the time of the event or interaction through the creation and scanning of a QR code, each using the respective apps;
- Users also may export a summary of stored data (using email) in a Comma Separated Value (CSV) file format. Users can email themselves the data to store on a computer or other device, and can refer to it when reviewing transactions annually; and
- When users purchase a new mobile device, they will not be able to transfer information from an old device to the new device. CMS suggests that users export the information to another device before discontinuing use of their old device.