Open Payments Database:  Be Sure to Review Before End of 2018

ASCO wants to help participants in its activities to successfully report their disclosures. Annual review of payments reported under your name in the U.S. Federal Government’s Open Payments website is an essential part of disclosure compliance. With all transfers of value being reported publicly by health care companies through the CMS Open Payments database (research payments, reprints, meals, travel, textbooks, etc.), you will want to be sure to review your profile for accuracy on an annual basis.

For 2018, physicians have until December 31 to review publicly available data and dispute inaccuracies for 2017 data. It is important to remember that data may only be disputed in the year it is first published.

Each year, the previous year’s data is published in June. The data for 2017 was published on June 30 of this year, along with newly submitted, corrected or updated payment information for 2013-2017. New updates/corrections will be added in January 2019 and will include any changes that have been made after June 2018. 

Again, 2017 data that was published in the Open Payments website on June 30, 2018, may only be disputed until Dec. 31, 2018. 

It is also important to note that physicians are given the opportunity to review data that has been attributed to them BEFORE it is released to the public. The time to preview before public release was April 1, 2018 – May 15, 2018. To review the data in advance and take any corrective actions, physicians must first register in the Open Payments system.

Open Payments and ASCO Activities

ASCO may be required to report certain payments made from manufacturer funding to U.S. physicians. Payments or transfers of value made to physicians indirectly through a professional organization like ASCO or a charitable organization like the Conquer Cancer Foundation are reportable if the manufacturer knows that money will be paid to physicians or earmarks money to go to physicians.

ASCO Conflict of Interest Policy

ASCO uses a general disclosure model, requiring disclosure of relationships regardless of their relevance or connection to a particular ASCO activity. The Open Payments database is populated by companies that make payments to physicians, and not by ASCO. All participants in ASCO activities are encouraged to double check their ASCO disclosure against other sources – including Open Payments – to identify any publicly reported interactions with Companies that may have been inadvertently omitted.

How to Register and Review Your Data

Physicians must use the CMS Enterprise Portal to review, affirm, or dispute their Open Payments data. To get started:

  • Complete an e-verification process by logging into the CMS Enterprise Portal (EIDM).  
  • Register in the Open Payments Program.
  • Review and dispute data by Dec. 31 of the current year
  • The Open Payments User Guide provides step-by-step instructions.

Key Dates for an Open Payments Program Year

Program Activities Program Timeline
Industry collects data January 1-December 31 of program year
Industry submits and attests to data in the Open Payments system February-March of the calendar year after the program year
Physicians and teaching hospitals review the reported data and dispute any data they believe is inaccurate; Industry makes corrections to the data (reflected in the initial publication)

Review and dispute period: April-May

AM/GPO Correction period: May-June

Initial program year initial data publication Prior program year data refresh publication June 30
Physicians and teaching hospitals continue to review and dispute data; industry continues to make corrections to the data (reflected in the data refresh publication) June 30  – December 31
Open Payments data refresh Early in the following year

Important Reminders

  • Companies will report all payments or transfers of value—including payments for research, travel, honoraria and speaking fees, meals, educational items like textbooks and journal reprints—whether made directly to a physician or teaching hospital or indirectly through a third party.
  • Because CMS only requires reports annually, a lengthy gap could occur between when the payment is made and when the report becomes available to a physician from CMS.
  • Physicians can ask companies to make them aware that the company plans to make a report.
  • Physicians can ask companies to develop a mechanism for challenging a planned report
  • ASCO and the Conquer Cancer Foundation have made a commitment to physician members to clearly communicate in advance when an ASCO or Foundation activity could result in a report. Members will have the opportunity to decline participating in an activity to avoid having ASCO report information back to a manufacturer.  
  • ASCO will continue to communicate important information regarding disclosure responsibilities.

Resources From CMS

The Centers for Medicare & Medicaid Services’ (CMS) Open Payments Program was created to bring transparency to financial relationships between physicians, teaching hospitals, and the pharmaceutical industry by publicly publishing data on financial interactions. The Open Payments database is designed to increase access to, and knowledge about, such relationships. Anyone may access, search and download the data. ASCO supports public disclosure of relationships with companies as one essential element critical to maintaining both professional and public trust.