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CMS Open Payments Reminder: Healthcare Provider Review and Refute Period Is April 1 – May 15

The federally run CMS Open Payments program provides transparency and increases public awareness of financial relationships between the healthcare industry and certain healthcare providers and teaching hospitals. This is accomplished by collecting and making public any payments or transfers of value from drug and device manufacturers to certain healthcare providers or teaching hospitals.

The Open Payments program includes these providers:

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

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.

On April 1, CMS will begin the 45-day dispute period when healthcare providers can review their 2023 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.

Each YNHHS provider is responsible for reviewing their 2023 data and disputing any inaccurate information during the review and dispute period, April 1 - May 15. To do so, providers must register on the CMS Enterprise Portal and the Open Payments System:

YNHHS’ Office of Privacy and Corporate Compliance (OPCC) will review applicable CMS Open Payments data once it’s released June 30 and may contact providers about their data if it is not aligned with their most recent Conflict of Interest disclosure survey responses.

Providers should ensure all interactions with drug and device manufacturers comply with the Interactions with Vendors policy:

For more information visit the OPCC Sharepoint site: and the Medical Staff Portal: Questions or concerns? Contact the OPCC, 203-688-8416 or [email protected].