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US Sunshine Act : CMS Releases Third Year of Open Payments Data

Pharma Compliance Digital CRM Marketing Transparence DMOS Shantanu Agrawal small US Sunshine Act : CMS Releases Third Year of Open Payments DataBy Shantanu Agrawal, M.D., CMS Deputy Administrator for Program Integrity

On June 30, 2016, the Centers for Medicare & Medicaid Services (CMS) posted the Open Payments data for program year 2015, along with newly submitted and updated 2013 and 2014 records.  Open Payments (sometimes called the Sunshine Act) is a national program, required by the Affordable Care Act, that promotes CMS’ commitment to transparency by providing data on the financial relationships between the health care industry – including pharmaceutical and medical companies – and health care providers.

In program year 2015, health care industry manufacturers reported $7.52 billion in payments and ownership and investment interests to physicians and teaching hospitals.  This amount is comprised of 11.90 million total records attributable to 618,931 physicians and 1,116 teaching hospitals.  Payments in the three major reporting categories are:

  • $2.60 billion in general (i.e., non-research related) payments
  • $3.89 billion in research payments
  • $1.03 billion of ownership or investment interests held by physicians or their immediate family members

Over the course of the Open Payments program since 2014, we have published 28.22 million records, accounting for $16.77 billion in payments and ownership and investment interests.

Posting the Open Payments program 2015 year data is exciting not only because we’ve concluded the third reporting cycle for Open Payments, but also because we are now able to compare the data across years to identify trends.  We are also able to analyze payments related to covered drugs, devices, biologicals, and supplies.  For example, we were able to determine that for program year 2015, 2.26 percent (637,131 records) of all financial transactions between physicians and pharmaceutical companies was related to opioid medications.

The Open Payments program provides the public more information about the financial relationships between physicians and teaching hospitals and the health care industry. The Open Payments Program does not identify whether financial relationships are beneficial or may indicate conflicts of interest.  Rather, this transparency program was intended to shed light on the nature and extent of these relationships.

We found that while the totals by major reporting category remained relatively unchanged between 2014 and 2015, there were some shifts in who was paid and how the money was spent.  See Table 1 and Figure 1 below.  Transparency is empowering physicians to be purposeful about their financial relationships with companies, and there is a notable shift towards charitable contributions and away from other interactions such as honoraria and gifts. We also observed some shifts in the highest paid physician types that may be of interest to researchers and other stakeholders. Coming years will provide additional interesting trend information.

Table 1: Highest Paid Physician Types, 2014 and 2015

Pharma Compliance Digital CRM Marketing Transparence DMOS open payment table2 US Sunshine Act : CMS Releases Third Year of Open Payments Data

Figure 1: Percent Change of Total Dollar Value by Nature of Payment, 2014 – 2015

Pharma Compliance Digital CRM Marketing Transparence DMOS open payments blog image US Sunshine Act : CMS Releases Third Year of Open Payments Data

Health care industry manufacturers must report to the Open Payments program annually, while participation by physicians and teaching hospitals is voluntary and encouraged.  If physicians or teaching hospitals disagree with what’s been reported, they can initiate a data dispute against the record and work with the reporting entity to resolve the discrepancy before the data is published. This process helps verify the accuracy of the Open Payments data. Registered physicians and teaching hospitals disputed 0.13 percent of Open Payment records (16,653 disputed records) that were eligible for review and dispute, representing 1.95 percent of total value of the published records.  Additionally, 0.22 percent of records (28,955 records) were affirmed by physicians and teaching hospitals, accounting for 0.76 percent of total value of the published records. Registered physicians and teaching hospitals with data attributed to them in the Open Payments system account for 35.45 percent of the total value of their published data. This does not include research-related payments made to non-covered recipients that employed physician principal investigators, which accounted for 40.92 percent of the published payments value.

If disputes are not resolved by the end of the data correction period, those entries are published with a notation identifying them as “disputed.”  We encourage physicians to sign up for Open Payments and to actively monitor any financial data related to them that is being reported.

Open Payments is part of CMS’ ongoing effort to increase transparency and accountability in health care. Since last publication (June 30, 2015), Open Payments has been referenced over 2,600 times in broadcast placements, traditional print, and social media.  Open Payments has been highlighted as a resource for transparency and reporting in an industry with complex stakeholder relationships that traditionally have been difficult to quantify and qualify.

You can search the Open Payments data at: OpenPaymentsData.CMS.gov. We’re pleased that the public has searched Open Payments data more than 6.78 million times. If you’ve visited the Open Payments website in the past, you’ll notice that we’ve improved our data review tools and provided a number of ways to accommodate different users and their interests:

  • Search Tool: Site visitors can get immediate results using this standard search interface to find detailed information on individual physicians, teaching hospitals, or companies making payments. Search results will now be aggregated in alphabetical order by the company reporting the payment.
  • Data Explorer: You can select a dataset and customize the view using filters, sorts, and other actions to create your own, targeted views of the data along with visualizations, such as charts and graphs.
  • Data downloads: You can download the data in comma-separated values (.csv) format, which allows you to open and explore the data using your own software on your own computer. With this option, you must have robust data viewing software that allows for downloading and viewing data in large datasets.

Open Payments continues to be an important program for health care transparency and we look forward to its on-going contributions to dialogue on the policy and clinical communities.
We also invite input on how to continue to improve this program. You can learn more about Open Payments by visiting CMS.gov/openpayments.

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