The Centers for Medicare and Medicaid Services (CMS) recently announced certain updates for the 2014 Open Payments data collection period. These updates include:
- Publication of a 2014 teaching hospital list
- Establishment of 2014 de minimis reporting thresholds
- Clarification of 2014 submission file specifications
Parties affected by the Open Payments program can benefit from keeping track of these and other updates to the Open Payments program, such as updates to CMS FAQs related to the Open Payments program and meetings related to implementation of Open Payments program requirements.
2014 Teaching Hospital List
Federal reporting requirements under the Open Payments program require applicable manufacturers to report annually to CMS certain payments or other transfers of value provided to covered recipients, including physicians and other health care professionals and “teaching hospitals.” Covered recipient “teaching hospitals” are defined at 42 C.F.R. § 403.902 as hospitals that received payment for Medicare direct graduate medical education (GME), inpatient hospital prospective payment system (IPPS) indirect medical education (IME), or psychiatric hospitals IME programs during the last calendar year for which such information is available to CMS.
CMS publishes a list of covered recipient teaching hospitals annually. CMS has explained that only hospitals on this list are considered teaching hospital covered recipients for Open Payments reporting purposes. CMS recently published the teaching hospital list for the 2014 Open Payments program data collection period. Applicable manufacturers will use this list for the 2014 Open Payments program data collection period only (i.e., applicable manufacturers continue to use the 2013 teaching hospital list for the 2013 data collection period). One notable difference in the 2014 teaching hospital list is that CMS is now including an entity’s common business name in addition to its legal business name. CMS believes this change will help to make the data more easily understood by users, as well as easier to collect for applicable manufacturers and applicable Group Purchasing Organizations (GPOs).
2014 De Minimis Reporting Thresholds
Per 42 C.F.R. §403.904(h)(2)(i)(2)(i), de minimis payments or other transfers of value are excluded from Open Payments reporting requirements. In calendar year 2013, the reporting requirements exclude payments or other transfers of value less than $10, unless the aggregate amount transferred to, requested by, or designated on behalf of a covered recipient exceeds $100 in the calendar year. CMS updates these de minimis thresholds annually. CMS announced that for calendar year 2014, if a payment or other transfer of value is less than $10.18 it is excluded from reporting, unless the aggregate amount transferred to, requested by, or designated on behalf of a covered recipient exceeds $101.75 in the calendar year.
2014 Submission File Specifications
CMS announced that, for the 2014 Open Payments program data collection period, there are no changes to the submission file specifications (formerly known as data collection templates) for reporting data to CMS. CMS will post future updates by October 1st of each year. The current submission file specifications include: