As we discussed here, the launch of the Centers for Medicare and Medicaid Services (CMS) Open Payments database on September 30, 2014 was met with a high level of criticism from industry, health care professionals, the media and other interested parties. One significant complaint was that the data was not easily searchable. Late last week, CMS provided a search tool option where users can search “identified data” for physicians, teaching hospitals, or companies using name, city, state or specialty. “Identified data” is data that (i) was matched by CMS to a single doctor or teaching hospital, and (ii) available for review and dispute for 45 days. However, as we previously discussed, a significant quantity of the data launched on September 30th was deidentified and, thus, not available using this search tool.
CMS also announced that applicable manufacturers and group purchasing organizations (GPOs) have until close of business on Friday, October 31st to make corrections to any 2013 Open Payments disputed records for publication this year. Although data corrections can be performed in the Open Payments system at any time, any corrective action taken by October 31st will be reflected in a refreshed data publication on or before December 31, 2014. Significantly, however, if a data correction results in a change to the covered recipient, any records are submitted to the Open Payments system for the first time, or any records currently on display are modified, the data will NOT be published as part of the December 31st data refresh because the data will not have undergone a review and dispute period.