Open Payments Database:  Review and Dispute Period Now Open

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 helpful way to make sure that information reported about you is accurate. 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 2019, physicians may review and dispute any inaccuracies for 2018 data before it is made public on June 30. The review and dispute period begins on April 1 and ends May 15. It is important to remember that data may only be disputed in the year it is first published. Review of the data is voluntary, but strongly encouraged to help improve the accuracy of the reported data.

To review the data in advance and take any corrective actions, physicians must first register in the Open Payments system.

If you miss the 45-day review period, be sure to check your data on June 30. Providers will be able to review and dispute the public data until December 31, 2019. The opportunity to dispute data will expire at the end 2019 and cannot be disputed after that.

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.