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CMS Reporting Structure Changes for Life Sciences Companies

We’ve written about changes introduced by the CMS in the reporting structure for applicable manufacturers and GPOs about ten months ago. We revisit those today, observing how those changes enable applicable medical drug and device manufacturers in the spend submission process.

Data Entry Ease

Submitting spend reports for entities overseas? Made R&D payments to HCPs and teaching hospitals outside the USA? With the features added to the CMS last year, compliance practitioners should find it easier to record identifiable information, such as international dialing codes.

The interface has also been simplified, making it easier for first-time users to navigate straight to the page of their choice. Syntax-related issues, such as errors arising from apostrophes, accent marks, etc., have been eliminated in the system upgrade. This might make the case of double-entries or wrongly identified physicians slightly more precarious, though.

More Detail

Spend review is one area in the Open Payments System that has undergone the most visible expansion. There is more detail per record on the attestation page. We anticipate that changes made to disputed transactions will be easier to identify with the ‘submission file error log,’ where the exact ToV causing the error will be displayed in a separate error for each field.

What this means is less drill-down and less combing through each record to identify double entries and other errors. These will be accompanied by access by HCPs and HCOs to records’ history, including associated disputes that the reporting entity deleted. Applicable manufacturers and GPOs will now also have about twice as much space as to record notes against spend disputes—up from 4,000 characters last year.

Richer Data Repository

One of the biggest advantages applicable manufacturers will face, thanks to CMS’ regularly replenished Open Payments database, is the ability to shorten their ‘search’ cycle. It will now be possible for them to identify physicians with expired state license numbers, as well as shift directly analysis from submission using the ‘Payment Type’ menu.

We expect that other changes—such as the introduction of an interactive helpdesk in the system, ensured the efficiency and troubleshooting they were supposed to bring.

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