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Physician Payments Sunshine Act - Open Payments
- From CMS: payment data for calendar year 2019 is now publicly accessible on the CMS Open Payments web site.
- The deadline for submitting disputes for 2019 payments is December 31, 2020.
- View published payment data for 2019 and for prior years
- Any questions from journalists, other members of the media or any other outside organization regarding payments listed on the Open Payments web site should be referred to JHMedia@jhmi.edu.
Note: The information on this site is provided to members of the Johns Hopkins Medicine Community as a resource for the Physician Payments Sunshine Act, which is also referred to as Open Payments.
- Overview of the Sunshine Act and Implications for Johns Hopkins Physicians
- Key Dates and Important Information
- Other Key Elements of Open Payments
The Sunshine Act requires that detailed information about payments and other “transfers of value” worth over $10 from manufacturers of drugs, medical devices and biologics to physicians and teaching hospitals be made available to the public. A physician is defined as a M.D., D.O., D.D./D.D.M., D.D.S., D.P.M., O.D. and D.C.P. who is licensed in any state in the U.S., whether or not they are practicing. The Act does not affect faculty and staff members who are not physicians.
The Act has implications for Johns Hopkins physicians who consult, serve on scientific advisory boards, or engage in other compensated activity in a personal capacity for manufacturers of drugs, devices or biologics. Details of the compensation for these activities, including the purpose of the payment, are posted on a publicly accessible website that is maintained by the federal Centers for Medicare and Medicaid Services (CMS).
Physicians may review and, if necessary, dispute reported payments. Individual physicians, not the physician's employer, are responsible for reviewing the accuracy of reported data and submitting disputes if the data are inaccurate.
The first cycle of payment data (covering payments made August 1 through December 31, 2013) became publicly accessible in September 2014. The second cycle of payment data covered the full calendar year 2014 and became publicly accessible on June 30, 2015. Calendar year data continues to be published annually. Physicians can view their previously published data for 2013-2019 by searching for their name on the Open Payments web site: https://openpaymentsdata.cms.gov/search
- Manufacturers have reported to CMS any payments made to physicians during the calendar year 2019 and any corrections to previously reported payment data.
- This data became publicly accessible on July 1, 2020.
- While the pre-publication review and dispute period has closed, physicians can still dispute inaccurate payments until December 31, 2020. The dispute will not be reflected on the CMS web site, but manufacturers will be notified of the dispute.
- Physician payment data includes individual general payments as well as institutional research payments for which the physician is identified as a Principal Investigator.
In order to review and dispute reported payments, physicians must be registered in the Open Payments system. Registration is a two-step process. Physicians must first register in the CMS Enterprise Identity Management (EIDM) System and then register in the Open Payments system.
Registration information is available at cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Physicians.html
For step-by-step instructions on the registration process, click here
If you registered previously, you may be required to reset your password. Accounts are locked if there has been no activity within the past 60 days and deactivated after no activity for 180 days. CMS has specific requirements for passwords which can be found here
You should allow sufficient time to complete the registration process and be aware that the CMS Help Line has limited hours.
Review and Dispute:
While the pre-publication review and dispute period has closed, physicians can still dispute inaccurate payments until December 31, 2020. Physicians are advised to review their reported 2019 payments for accuracy and submit any disputes to Open Payments. CMS will then notify the manufacturer of the dispute. Physicians should work with the manufacturer to resolve the dispute and correct any inaccuracies. Manufacturers have generally provided contact information in Open Payments to assist physicians in resolving disputes.
Information about the review and dispute process is available at https://www.cms.gov/OpenPayments/Program-Participants/Physicians-and-Teaching-Hospitals/Review-and-Dispute.html
If physicians initiate disputes regarding either (i) payments of a significant dollar amount, or (ii) a significant number of individual payments, they should advise the Office of Policy Coordination at email@example.com.
To determine whether the reported payment data are accurate, physicians are advised to maintain records of the payments they receive from manufacturers.
At Johns Hopkins, research payments are made to the institution and not to individual physicians. Research payments are displayed in a dedicated section of the Open Payments database. The Sunshine Act requires that manufacturers identify up to five Principal Investigators in connection with research payments made to the institution.
Physicians are able to review and dispute their designation as a Principal Investigator in connection with institutional research payments.
- Please be aware that the CMS definition of Principal Investigator may differ from that used within Johns Hopkins Medicine. As a result, manufacturers may designate co-investigators as Principal Investigators in the Open Payments database.
- Physicians designated as a Principal Investigator can only dispute their association with the payment. Other payment details must be disputed by the covered recipient of the payment.
- Payments to physicians that are related to research but not covered by an institutional research agreement may still be attributed to physicians as personal payments (e.g., travel or medical writing and editing services).
- Manufacturers must collect and provide information about indirect payments as well as payments made directly to physicians. For example, if a physician is paid indirectly through a third party (e.g., contract research organization, travel agency), the payment will be listed as a transfer from the manufacturer to the physician.
- Payments to physicians for serving as speakers at accredited Continuing Medical Education activities are generally not included. This can vary depending on the specific details of the payment.
- Manufacturers are responsible for reporting payments to CMS; physicians and research institutions are not responsible for reporting to CMS.
- Manufacturers must identify physicians by their National Provider Identifier (NPI), so physicians may be asked to provide their NPI to a company that has made payments to them, whether directly or indirectly.
- Categories of payments and transfers of value to physicians include, among others, consulting fees, compensation for speaking, travel, food, entertainment, gifts, honoraria, royalties, education, research, current or prospective ownership or investment interest, etc.
- Information about payments to teaching hospitals will be listed by hospital name. The teaching hospitals that are part of Johns Hopkins Medicine are the Johns Hopkins Hospital, Johns Hopkins Bayview Medical Center, Sibley Memorial Hospital, Suburban Hospital and Johns Hopkins All Children's Hospital.
Patients may have questions about the payments their physician received. Suggested guidelines for responding to patient questions are available here. Responses should be adapted for each individual situation to ensure that the information provided is accurate.
- For questions about registration and other technical assistance, contact the CMS Open Payments Help Line at 1-855-326-8366 or firstname.lastname@example.org. The Help Line is available Monday through Friday from 7:30 a.m.-6:30 p.m. (CST) although there may be changes to that schedule due to the corona virus outbreak. For step-by-step instructions on the registration process, click here.
- For information about the review and dispute process, click here. After noting a payment as disputed on the CMS Open Payments website, physicians must contact the manufacturer directly to resolve the dispute and correct any inaccuracy.
- Faculty and investigators who have questions about Sunshine payment data and the School of Medicine disclosure requirements should contact email@example.com.
- All other questions should be directed to the Office of Policy Coordination preferably by e-mail to firstname.lastname@example.org. Voicemails can also be left at 410-361-8667 and will be answered as soon as possible, but please note that our staff are all working remotely at this time.
CMS procedures are subject to change and this site will be periodically updated.
Last update: September 4, 2020.
Posted February 26, 2015
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