The Centers for Medicare and Medicaid Services (CMS) held a webinar today to address the process for correcting and resubmitting records that were removed from the Open Payments system in August 2014 by CMS due to data integrity issues.  CMS started the webinar by stating that of the 4.4 million records disclosed to the public on September 30, 2014, 1.7 million records ($2.2 billion) were “deidentified” due to these data integrity issues.  CMS also disclosed that another 199,000 records ($1.1 billion) were not published because (i) the payments were under dispute at the time of publication; (ii) applicable manufacturers had requested delayed publication of the research payment; (iii) the payment was a research payment related to a non-covered recipient; or (iv) records that were submitted or attested to on July 7th, the last day of data submission and attestation, were excluded due to a technical issue by CMS when it pulled the data for publication.

CMS explained that the data integrity issues were caused by data inconsistencies between the NPPES and PECOS databases, which contain physician information, including names, license numbers and NPI numbers.  As a result, CMS is implementing an enhanced data matching and validation process, depicted by CMS as follows:

CMS enhanced process

Most interestingly, CMS confirmed that records previously identified as a data issue and withheld from publication could, in fact, be appropriate.  This means that the applicable manufacturer or group purchasing organization (GPO) could resubmit the payment without a change.  All resubmitted payments will be placed “on hold” in the Open Payments system until CMS’s enhanced matching process is put into place by 1/31/15.  These records, as well as all records submitted as part of the 2015 data submission period for calendar year 2014, will be included in the review and dispute period that will take place after the data submission period closes on 3/31/15.  CMS further confirmed that during its data publication on 6/30/15, it plans to publish all resubmitted 2013 data and 2014 data in whole and fully identified.

Industry was clearly interested in this webinar.  The webinar generated a significant number of questions related to the process for fixing and resubmitting data to CMS, as well as ongoing issues related to data matching.  At one point, CMS stated that there was a queue of 300 questions submitted online.  This was in addition to a robust live Q&A dialogue, in which several industry participants noted that physicians with data in the NPPES or PECOS systems are not included in the validated physician list provided by CMS or otherwise are still generating data issues.  CMS responded that it plans to provide an updated physician list in early 2015.

CMS ended the webinar by stating that it is open to more frequent interactions with industry, even “far more frequently if helpful.”  In discussing this concept, CMS stated that it is in CMS’s “best interest” to stay in better contact with industry and respond timely to questions and issues.  While CMS is considering how best to implement this, it may include some informal open sessions or Q&A dialogues.  We will keep you updated on this blog with any developments.

Posted by Cooley

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