June 30 marks an important milestone in healthcare transparency: The Centers for Medicare & Medicaid Services (CMS) releases updates to the Open Payments™ Database. The Open Payments™ Database houses information on payments made to physicians and teaching hospitals by drug, device, biological, and medical supply manufacturers—known as Reporting Entities. This is important because it fosters transparency of financial relationships by disclosing payments made by pharmaceutical and medical device companies to physicians. It is a backstop to an organization’s conflict of interest disclosure requirements, helping to prevent false claims and Stark Law violations.
Recently, the CEO of a medical device company in Massachusetts pled guilty to one count of a false statement. Employees were reportedly directed to mislabel payments as consulting fees. To read more about this case, click here.
This case highlights the importance of organizations having a thorough process in place to review physician payments. By completing this review, your organization can identify potential Conflicts of Interest (COI) or payments that would implicate Stark or Anti-Kickback Statutes. Additionally, a review identifies any possible errors in payment. If errors are identified, they should be disputed with the Reporting Entity.
LW Consulting, Inc. (LWCI) currently completes this work for clients. We developed a process to use physicians’ National Provider Identifier (NPI) numbers to find and compile all relevant payment data into an Excel file for easy client review.
After analyzing the data released last year, LWCI published a case study outlining our audit process, including key findings and strategic recommendations. Download the case study to learn more.
Does your organization need assistance in completing the Open Payments™ Database review? LWCI can help! Contact us to schedule a conversation to learn more.
