Open Payments Review and Dispute Period Now Open - McDermott+Consulting

Open Payments Review and Dispute Period Now Open

The Physician Payments Sunshine Act requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal health care programs to report certain payments and items of value given to physicians and teaching hospitals. CMS has implemented this mandate through the Open Payments Program. As part of this program, manufacturers are required to submit annual data on payment and other transfers of value that they make to covered recipients. The data submissions period is followed by 45 days for providers to review their data and dispute errors before its public release.

The review and dispute period for the June 30, 2016 publication began on April 1, 2016 and will last for 45 days through May 15, 2016. In order to review the data, physicians and teaching hospitals need to register in the Open Payments system.  Providers can register on the CMS Open Payments website. CMS will publish the 2015 payment data and updates to the 2013 and 2014 data on June 30, 2016. The chart below describes the data that has been submitted and publically posted so far.

Total US Dollar Value $9.92 billion
Total Records Published 15.71 million
Total Companies Making Payments 1,615
Total Physicians with Payment Records 682,000
Total Teaching Hospitals with Payment Records 1,144


The implementation of Open Payments has not been without its problems. In previous years, manufacturers and group purchasing organizations have experienced problems submitting data to the online database. Physicians and teaching hospitals have reported problems registering and logging into the database. Even CMS has had problems with data consistency and accuracy which resulted in them withholding portions of submitted data in past years.


To help address and resolve problems as they emerge, CMS has posted various resources on the Open Payment website and established an Open Payments Help Desk ( CMS has also posted a slide presentation from a recent conference call that provides details on the current review and dispute period.