New providers added to Open Payments program 

CMS Open Payments is a federally run program that provides transparency and increases public awareness of financial relationships between the healthcare industry and certain healthcare providers and teaching hospitals. This is accomplished by collecting and making public any payments or transfers of value from drug and device manufacturers to certain healthcare providers or teaching hospitals. 

Open Payments requires that all transfers of value from an industry representative to certain healthcare providers or teaching hospitals valued at or above $10 or aggregate of $100 per year be reported. Transfers of value may include food and beverage, entertainment, charitable contributions, speaking fees, royalties or licenses, grants, consulting fees, honoraria, travel and lodging, education, research and more. The nature and purpose of the amount must also be recorded and disclosed.

The Open Payments program has expanded to include five new provider types. While drug and device manufacturers are required to collect this data in 2021, it will not be available for review until April 1, 2022. The provider types below should ensure that all interactions with drug and device manufacturers comply with YNHHS’ Interactions with Vendors policy (in network only):

• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists and anesthesiologist assistants
• Certified nurse-midwives

For physicians, the CMS review and dispute period will run April 1 – May 15, 2021. Starting April 1, physicians can review their 2020 data posted by drug and device manufacturers. The review and dispute period provides physicians the opportunity to dispute any inaccurate or incomplete data before it is published for the public on June 30, 2021. Each YNHHS physician is accountable for reviewing their 2020 data and disputing any inaccurate information during CMS’ review and dispute period. Yale New Haven’s Office of Privacy and Corporate Compliance (OPCC) will review applicable CMS Open Payments data once it’s released June 30 and may contact physicians about their Open Payments data if it is not aligned with their most recent Conflict of Interest disclosure survey responses. 

For more information, visit the OPCC site on the employee intranet (in network only); call (203) 688-8416; or email [email protected].