On October 1, 2013, the Centers for Medicare and Medicaid Services (“CMS”) posted the 2014 Teaching Hospital List on its OPEN PAYMENTS website. The final regulations implementing the Transparency Reports and Reporting of Physician Ownership or Investment Interests section of the Patient Protection and Affordable Care Act define a “teaching hospital” as “any institution that received a payment under 1886(d)(5)(B), 1886(h), or 1886(s) of the Act during the last calendar year for which such information is available.” In order to assist applicable manufacturers in identifying teaching hospitals, CMS stated that it will publish a list of the relevant teaching hospitals “at least 90 days before the beginning of the reporting year, or for the first reporting year, at least 90 days prior to the start of data collection.” Even amidst the government shutdown, CMS released the 2014 Teaching Hospital List in a timely manner.
The 2014 Teaching Hospital List includes more information than CMS’ 2013 Teaching Hospital List. For example, the 2014 Teaching Hospital List includes a teaching hospital’s common business name, as well as its legal business name. CMS notes that for the 2014 OPEN PAYMENTS program cycle, data should be collected and reported using an institution’s common business name and not its legal business name. The data should be reported separately for each common business name and taxpayer identification number (“TIN”) combination appearing on the list.
The 2013 and 2014 Teaching Hospital Lists are available on the CMS OPEN PAYMENTS website at the following link: