U.S. Transparency Reporting: The Newly Added Covered Recipients

Open Payments requirement will now include five other additional provider types. Here are the entities that will be reported from 2022 onwards:

  • Physician assistants

  • Nurse practitioners

  • Certified nurse-midwives

  • Clinical nurse specialists

  • Certified registered nurse anesthetists and anesthesiologist assistants

Before submitting your data, it is highly recommended that you thoroughly review it to ensure that covered recipients are included in your reports and that the reports are created in the CMS-preferred format.

Leveraging a data-driven aggregate spend reporting platform is critical for aggregate spend reporting. It enables compliance professionals to minimize the challenges involved in preparing aggregate spend reports.

An automated and data-driven transparency reporting platform also significantly reduces the time required to prepare spend reports by allowing compliance teams to identify errors such as duplications, validate data through 400+ built-in rules, generate risk-free reports through the platform, and ensure timely submission of your federal reports.

Checking the Accuracy of Your Data (For Covered Recipients)

You can review the data attributed to you to see if the data is accurate. You can always file a dispute if you find the data inaccurate or misleading.

In addition, know that the reviewal of your data on the Open Payments website is voluntary and is encouraged by the CMS mainly to ensure the accuracy of the data submitted by hundreds of Life Sciences and Pharmaceutical companies.

Covered recipients are provided a 45-day pre-publication review and dispute period. The purpose is to give reportable entities time to evaluate the accuracy of their data before the Centers for Medicare & Medicaid Services (CMS) publishes it.

The Importance of Reviewing Data

Reviewing data allows covered recipients to ensure that the information associated with them is accurate. For compliance professionals, Life Sciences, and Pharmaceutical companies, however, reviewing their aggregate spend data before submitting reports to the CMS is an unavoidable imperative.

Collecting, validating, and preparing aggregate spend data can be challenging if the compliance teams are not utilizing a data-driven compliance platform.

Through data-driven compliance platforms, compliance teams can reduce the complexity involved in preparing spend reports, ensure accuracy and efficiency, and improve the overall process of preparing and submitting aggregate spend reports on time.

How Can an Organization Participate in Open Payments?

For participation in Open Payments as a reporting entity, Life Sciences and Pharmaceutical companies would have to:

· Register in the Open Payments System

· Collect, validate, and structure data as per CMS’s instructions and submit reports to the system

· Verify and attest to the accuracy of the data submitted to the CMS

· Respond to disputed payments

Open Payments Program cycles consist of a full calendar year. Reporting entities must submit their federal reports within the period provided by the CMS. Once the reports are submitted and analyzed by the CMS, the data is published each year on or by June 30th.

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