The Centers for Medicare & Medicaid Services (CMS) announced today that Phase 2 of the Open Payments reporting will begin on Sunday, June 1st and continue through Monday, June 30th. Instructions from CMS for Phase 2 are available here; additional information regarding CMS data submission resources and Phase 2 tutorials are available here. This Phase 2 reporting will consist of two steps:
Step 1 (June 1st – June 30th):
- Complete Open Payments system registration
- Confirm the accuracy of the reporting entity profile data submitted in Phase 1
- Delegate roles and responsibilities by nominating system users to fill specific user roles
- Perform test file uploads and submit data files to validate the file structure and contents of the file
- Utilize the error report produced by the Open Payments system to fix data errors (if any) in submitted files
Step 2 (June 9th – June 30th):
- Perform final data submission, including a series of checks to match the reported data to the appropriate physicians and teaching hospitals
- Attest to the accuracy of the submitted detailed 2013 payment or other transfer of value data and ownership or investment interest data. The attestation language is available here.
Manufacturers and group purchasing organziations (GPOs) also have the option of submitting an assumptions document to CMS during Phase 2. CMS announced that assumptions and methodologies may be provided to CMS via a free-form text field that can be entered directly or cut/paste from another document. Assumptions cannot be longer than 4,000 characters including spaces. CMS reiterated that submission of any assumption is voluntary and will not be made public.