The Open Payments Program facilitates greater transparency with regard to financial relationships between manufacturers, physicians and teaching hospitals. This legislation requires that manufacturers of drugs, devices, biologicals and medical supplies report to the Centers for Medicare & Medicaid Services (CMS) any payments or other transfers of value made to physicians and teaching hospitals.

  • "Physicians" include those who are legally authorized to practice medicine, osteopathy, dentistry, dental surgery, podiatry, optometry and chiropractic medicine (note that medical residents are specifically excluded from this definition).

Additional information for physicians about the Open Payment Program is available from the Centers for Medicare & Medicaid Services.

WCM Physician Requirements

  1. If you have not already registered with the CMS, register through the CMS Enterprise Portal
    Note: You may already have an Enterprise IDentity Management (EIDM) account if you use the Health Insurance Oversight System (HIOS), the Medicaid And CHIP Program (MACPro) System or other CMS systems.
  2. If you have not already registered for Open Payments, register through the CMS Open Payments System to review what has been reported about you and dispute it (if necessary).
  3. Ensure that your WCM Annual Survey Statement of External Financial Interests and External Time Commitments are complete, accurate and up-to-date.

Important Information for WCM Physicians

  • "Payments" are defined very liberally (e.g., meals or other items of value greater than $10 will be reported)
  • Reporting of payments is done by industry and not by WCM
  • WCM staff members do not have access to reported information and therefore cannot review this information for you
  • Open Payments information will be published on a public website and will likely be of interest to the press and others
  • WCM policy requires all faculty members to review Open Payments industry postings to ensure that the information is accurate and, when necessary, work with posting entities to correct inaccuracies

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