Ensuring adherence to Center for Medicaid and Medicare Services (CMS) requirements and maintaining transparency is important for life sciences companies. One critical aspect that demands attention is the correction and resolution of open payments disputes that are initiated by physicians, non-physician practitioners (NPPs), teaching hospitals all of which are collectively referred to as “covered recipients.”
The significance of correcting and solving disputes lies in the delicate balance between fostering collaborative relationships with healthcare professionals (HCPs) and abiding by the requirements of CMS reporting guidelines to ensure compliance.
Additionally, these disputes can disrupt the smooth functioning of how life sciences companies manage their transparency reporting requirements. Misunderstandings between parties and data inaccuracies are some of the reasons why disputes arise after CMS submission.
To tackle this challenge, compliance professionals, the unsung heroes behind the scenes, employ their expertise to address and resolve disputes. Their efforts not only aim to resolve ongoing contentions but also involve proactive measures to prevent disputes from arising after CMS submission.
One of the ways compliance professionals reduce the risk of disputes is by leveraging a data driven aggregate spend reporting platform. This enables them to identify potential pitfalls before data submission, safeguarding the organization against disputes in the long run and maintaining a healthy relationship with third parties.
Prerequisites of Addressing Open Payment Disputes
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User must be registered in the Centers for Medicare & Medicaid Services (CMS) Identify Management System and should have obtained access to Open Payments System
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The reporting entity needs be registered in the Open Payments System
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The users who correct and resolve disputes hold the role of “submitter user” for the reporting entity
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Step #1: Searching for Disputed Records in Open Payments System
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Log in to the Open Payment System via the CMS Enterprise Portal. You can access this at portal at https://portal.cms.gov/.
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Once you have logged in, select the “Review and Dispute” tab.
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Select the reporting entity and the appropriate program year from the drop-down menu. From the drop-down menu, select the “Show Disputes” button.
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When you’re on the “Review and Dispute” page, set the filter for “Review and Dispute Status” to “Acknowledge” or “” Once you’re done, select the “Search” button.
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On this page the user can:
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See the details about a specific disputed record by selecting the Record ID or the “View” option under the “Actions” column.
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See a detailed history of the record’s disputes by selecting the “View” option under the “History of Disputes”
Step #2: Correcting and Re-Submitting Data To The CMS
Data corrections can be made manually to individual records. You can also submit a bulk file with corrected records. Both the options have different approaches to them advised by the CMS. Here’s how you correct and re-submit data using both the options:
Option 1: Manually Correcting Records
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Go to the “Review and Dispute” page.
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Find the records that need correction.
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Select “Edit” under the “Actions” column.
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You can now edit the fields that require correction.
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Once you are done editing, click on the “Save Record” button.
Option 2: Correcting Records via Bulk File Upload
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Create a bulk data file that consists of the records that need correction. In the bulk file:
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Set the “Resubmission File Indicator” for the records to be corrected to “Y.”
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Include the original Record ID that the Open Payments system created in the “Resubmitted Payments Record ID” field.
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Note that it is important for the system to accept the corrected record as a resubmission not as a new record.
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Follow the standard upload process to submit the bulk file. Click here to read the instructions for “Bulk File Upload.”
Note: Once a record is in a “Ready for Attestation” or “Attested” status, the fields that identify as record’s covered recipient including the principal investigator cannot be changed.
However, there’s a possibility to correct these records by deleting the original records and then re-submitting the newly corrected records. Moreover, records can also be deleted from the “Review and Dispute” page in response to a dispute.
When a user from a reporting entity (applicable manufacturers) deletes or edits a disputed record, the CMS sends an email notification to the covered recipient who initiated/created the dispute.
In case the individual who created the dispute is a physician’s or NPP’s authorized representative with dispute access, the email notification is sent to the physician or NPP listed on the record as well.
Additionally, the records being edited, corrected, or deleted are available for the covered recipients to view.
It is also important for life sciences companies to know that resubmission of corrected payments/records to resolve disputes can affect the publication timing of the record.
CMS gives you 45 days to review everything and make any edits to the data submitted before it becomes publicly available on their website. Even if a dispute occurs after CMS submission, you have an additional 15 days to make corrections and resolve disputes.
CMS also notifies the Covered Recipients to review payments reported by life sciences companies through email list and online postings which include the CMS website and the Federal Register.
Step 3: Getting the Corrected Data Re-Attested
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The corrected, edited, or deleted data that was previously attested must be re-attested for the updates to be considered completed. For more information, visit the “Final Submission and Attestation” guide.
Once the corrected data is re-attested, the review and dispute status of the corrected records will be set to “Resolved.” The individuals who have initiated the dispute will receive an email notification that their dispute has been addressed.
Resources To Help You with the Review & Dispute Process
You can easily access the review and dispute process resources from the Resources page of the Open Payments website. Click here to visit the website. This comprehensive guide that CMS provides will help life sciences companies and compliance professionals to deepen their knowledge regarding the review and dispute process and learn the essential steps they need to take in specific scenarios.
The different guides present on CMS’s website that are relevant to resolving disputes include the following documents:
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Bulk File Upload
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Manual Data Entry
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Final Submission and Attestation
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Identifying Validation and Matching Errors
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Correcting Validation and Matching Errors
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Record Deletion
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Acknowledging Disputes and Resolving Disputes with No Change to Data
Conclusion
Even though life sciences companies continue to bring novel therapies and innovation to the healthcare sector, the importance of submitting accurate and complete data to the CMS cannot be overstated for life sciences companies.
Failure to do so can result in fines and penalties that can significantly impact the organization. However, by understanding how to address disputes effectively (which is only one part of the entire aggregate spend reporting process), life sciences companies can navigate the regulatory landscape with confidence, ensuring that they meet all Sunshine Act reporting obligations and maintain positive relationships with healthcare professionals.
qordata’s data-driven aggregate spend reporting solution augment the capabilities of your federal and state reporting process. It provides complete visibility into your data, allowing compliance professionals and life sciences companies to distinguish between reportable and non-reportable transactions. With the ability to edit multiple transactions with ease and remediate issues promptly, you can be certain that your reports are accurate and compliant.
Say goodbye to last-minute surprises in March and embrace a seamless, accurate, and timely preparation and submission of aggregate spend reports with qordata. Click here to schedule a demo.
Reference: Open Payments System Quick Reference Guide Correcting and Resolving Disputes
