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Providers: CMS Open Payments review and refute period is April 1 - May 15

The federal CMS Open Payments program provides transparency and increases public awareness of financial relationships between the healthcare industry and certain healthcare providers and teaching hospitals. 

To do this, CMS collects and makes public any payments or transfers of value from drug and device manufacturers to certain healthcare providers or teaching hospitals. Per Open Payments, all transfers of value from an industry representative to certain healthcare providers or teaching hospitals valued at or above $10 or aggregate of $100 per year are reported. Transfers of value may include food and beverage, entertainment, charitable contributions, speaking fees, royalties or licenses, grants, consulting fees, honoraria, travel and lodging, education, research and more. The nature and purpose of the amount will also be recorded and disclosed.

The Open Payments program includes:

  • MDs/DOs
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists and anesthesiologist assistants
  • Certified nurse midwives

For healthcare providers, the CMS review and dispute period will be April 1 - May 15. During this period, providers can review their 2022 data posted by drug and device manufacturers. This review and dispute period gives physicians and other covered recipients the opportunity to dispute any inaccurate or incomplete data before it is published to the public on June 30, 2023. Each YNHHS provider is accountable for reviewing their 2022 data and disputing any inaccurate information. Yale New Haven’s Office of Privacy and Corporate Compliance (OPCC) will review applicable CMS Open Payments data once it is released on June 30 and may contact providers about their Open Payments data if it is not aligned with their most recent Conflict of Interest disclosure survey responses. 

Providers should ensure that all interactions with drug and device manufacturers comply with the YNHHS Interactions with Vendors policy, available on the employee intranet under Policies.

For more information, visit the OPCC site on the employee intranet (under Departments & Communities), call 203-688-8416 or email [email protected]