By Ingrid A. Pelzer (@IngridPelzerPLS)
As previously reported, the Centers for Medicare and Medicaid Services (CMS) has adopted a two-phased approach for registration and submission of Sunshine Act data for the 2013 reporting year. Phase 1 of CMS' Open Payments registration and data submission process for applicable manufacturers and applicable group purchasing organizations (GPOs) began on February 18, 2014, and concluded on March 31, 2014. During Phase 1, applicable manufacturers and applicable GPOs were required to register in CMS' Enterprise Portal, and submit corporate profile information and aggregate 2013 payment data. According to CMS, Phase 2 is scheduled to begin late May/June 2014, and will run for no fewer than 30 days. During Phase 2, CMS will require applicable manufacturers and applicable GPOs to submit detailed 2013 payment data, and legal attestation to the accuracy of the data.
On May 1, 2014, CMS noted that when Phase 2 begins, the authorized officials for applicable manufacturers and applicable GPOs will need to complete the following actions:
- Log into the Open Payments System using their CMS user ID created during Phase 1, and complete Open Payments registration for both the entity and for themselves as authorized officials. Authorized officials who did not register during Phase 1 must do so in order to access the Open Payments System in Phase 2.
- Confirm the accuracy of the entity profile data submitted during Phase 1.
- Upload or enter, submit, and attest to the accuracy of the detailed 2013 payment or other transfer of value data, or ownership/investment interest data.
In Phase 2, authorized officials will be able to delegate roles and responsibilities within the Open Payments system by nominating individuals to fill specific user roles. Once delegated, these individuals will be permitted to perform the actions associated with their user roles.
In an effort to prepare applicable manufacturers and applicable GPOs for Phase 2, CMS has announced that it is currently developing a series of tutorial videos to explain:
- "How to prepare data submissions using the data submission resources, specifically, using the CSV and XML Sample Files and XML Schema Definition (XSD document) to format data for upload into the Open Payments system.
- How to register in the Open Payments system, explained through step-by-step screenshots.
- How to formally submit data files in the acceptable file formats to the Open Payments system, and attest to the accuracy of the data."
Please note that this two-phased approach to Open Payments registration and data submission is only for the 2013 reporting year, which includes data that was collected between August 1 and December 31, 2013. CMS has indicated that for the 2013 reporting year it will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission.