Published May 24, 2023

The Importance of Monitoring Financial Relationships Using CMS Open Payments

The Centers for Medicare and Medicaid (CMS) Open Payments is a national disclosure program that promotes a more transparent and accountable healthcare system by publishing certain financial relationships between applicable manufacturers and group purchasing organizations (GPOs) and healthcare providers (physicians, physician assistants, advanced practice nurses, and teaching hospitals). The Open Payments program maintains a consistent disclosure process to encourage ethical standards, prevent fraud and corruption, and encourage public awareness.   

Drug and medical device companies keep track of payments or other transfers of value they make to healthcare providers* and teaching hospitals and submit the data to CMS in January for the previous year’s payments. The Open Payments data is released in June for the previous calendar year.

Types of Payments in CMS Open Payments Database

The types of payments or other transfers of value reported in the database are these:

The Open Payments database is available to assist organizations with identifying potential relationships that might cause a conflict of interest or expose the company to potential violations of the Physician Self-Referral Law (Stark) or Anti-kickback Statute. The most prevalent disclosures and potential conflicts of interest involve medical device product selection, drug formulary selection, and clinical research.

Compliance officers should review the Open Payments data at least annually to determine if potential conflicts of interest or violations of company policies exist and should be addressed through an internal vetting process. Also, healthcare organizations are encouraged to monitor disclosures of outside/financial interests and potential conflicts as part of the provider onboarding process by reviewing the Open Payments database prior to employment.

Physicians, physician assistants, and advanced practice clinicians should check data reported in the system on a routine basis to assess accuracy of payments associated with them. Data is released to the public annually on or by June 30 and is refreshed at least once annually. 

Access the Open Payments database.

Read more about CMS Open Payments.

PYA has developed conflict of interest reporting software to assist organizations in capturing, analyzing, and monitoring disclosures. PYA’s Open Payments Dashboard is an interactive tool available to quickly analyze payments by applicable provider, specialty, or manufacturer. For example, with just two clicks, an organization can quickly view all the applicable providers receiving payments from a specific manufacturer, as well as the nature of those payments, in an easy-to-read format. PYA also can compare conflicts disclosed by providers via the organization’s disclosure policy to the payments reported by CMS.

View a video about the PYA Open Payments Dashboard to learn more.

PYA has professionals experienced in medical practice operations, billing, and regulatory compliance.  If you have questions about Open Payments, our executive contacts would be happy to assist. You may contact them at the e-mails below or by calling (800) 270-9629.

*Physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and anesthesiologist assistants, and certified nurse-midwives

Executive Contacts

Interested in Learning More?

Sign Up for Our Latest Thought Leadership!

    Select Your Subscriptions