The Open Payments Program facilitates greater transparency with regard to financial relationships between drug and medical device companies, and select healthcare providers and teaching hospitals (collectively referred to as "Covered Recipients"). 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 Covered Recipients.
- "Covered Recipients" are considered to be any physician, physician assistant, nurse practitioner, clinical nurse specialist, certified registered nurse anesthetist, or certified nurse-midwife who is not a bona fide employee of the applicable manufacturer that is reporting the payment; or a teaching hospital, which is any institution that received a payment under 1886(d)(5)(B), 1886(h), or 1886(s) of the Act during the last calendar year for which such information is available. (CMS Open Payments Glossary.)
Additional information for physicians about the Open Payment Program is available from the Centers for Medicare & Medicaid Services.
WCM Covered Recipient Requirements
- 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. - If you have not already registered for Open Payments, register through the CMS Open Payments System to review what has been reported under your NPI and dispute information (if necessary).
- Ensure that your WCM COI Survey reflects the details accurately reported in Open Payments.
Important Information for WCM Covered Recipients
- Payments are defined very liberally and can include consulting fees, education, food and beverage, gifts, honoraria, and grants, among other categories.
- 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.
- It is highly encouraged that WCM Covered Recipients review Open Payments industry postings to ensure that the information is accurate and, when necessary, work with posting entities to correct inaccuracies.
- The Office of Conflict of Interest performs an annual audit of reported data to ensure it aligns with your COI Survey.