On this accredited episode of NP Pulse: The Voice of the Nurse Practitioner®️, join representatives from the Centers for Medicare & Medicaid Services (CMS) as they provide an overview of the Open Payments program — a national initiative that promotes transparency in health care by tracking payments from drug and medical device companies to certain health care providers.
Since Jan. 1, 2021, nurse practitioners have been included as covered recipients. In this session, you’ll learn how the program works, explore key data insights and understand your role and responsibilities.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
(00:00):
(upbeat music)
- From the American Associationof Nurse Practitioners
I'm the host of today'sspecial edition episode,
nurse practitioner and educationspecialist Patty Scalzo,
(00:22):
and this is "NP Pulse", thevoice of the nurse practitioner.
(upbeat music continues)
Welcome to "NP Pulse",AANP's podcast bringing you
unique nurse practitioner voices
and expertise on issues that matter
to NPs and our patients.
(00:44):
As always, be sure tosubscribe to this podcast,
share with your colleagues,
and check back often for new conversations
with nurse practitionersand healthcare leaders
from across the nation.
"NP Pulse" podcast listeners may claim
CE credit for this programthrough August, 2026.
After you listen to the podcast,
visit aanp.org/cecenter,
(01:08):
register for this activity,
enter the participation code provided
at the end of the podcast,
and then complete thepost-test and evaluation.
On today's episode, we will be exploring
the Open Payments program,
a key element of professional practice
for nurse practitioners.
This national initiative promotes
transparency by publicly reporting
(01:30):
financial relationshipsbetween healthcare providers
and pharmaceutical ormedical device companies.
Whether it's consulting fees,
research payments, or even meals,
these interactions are recorded
in a searchable database open to anyone.
Understanding what's reported about you is
essential for maintaining trust,
(01:50):
ensuring accuracy,
and upholding ethical standards.
Let's take a closer lookat how the program works
and what it means for your practice.
Frank Harrington,
the Director of Reimbursementand Regulatory Affairs
at AANP will be moderatinga lively discussion
with members of theCMS Open Payments team,
Amy Bedsaul and VeronikaPeleshchuk Fradlin.
(02:13):
It is my pleasure to welcomethis panel of experts.
- Welcome to "Open Paymentsand the Nurse Practitioner,
Your Role in the TransparentHealthcare System".
Today we are excited to welcome
members of the CMS Open Payments team
who will share information and updates
about the program with you.
I'm Frank Harrington,
AANP's Director of Reimbursementand Regulatory Affairs,
(02:36):
and I would like you to meetour guests, Veronika and Amy.
Veronika, would youplease introduce yourself?
- Hi, Frank.
I'm Veronika Peleshchuk Fradlin,
Director of theTransparency and Data Group
at CMS Office of HealthcareExperience and Interoperability,
and it's great to be here.
Thanks so much for having us.
(02:57):
- Thank you so much forbeing here today, Veronika.
And Amy, would you pleaseintroduce yourself?
- Hi, I'm Amy Bedsaul.
I do the Open Paymentscommunications activities.
It's just great to behere with everyone today.
We're excited to shareinformation about the program.
- Thank you so much, Amy.
And so Veronika, we would love to hear
about the background of the program.
(03:18):
So what exactly is theOpen Payments program?
- Sure.
Open Payments is anational disclosure program
that provides transparencyinto financial relationships,
healthcare providers suchas nurse practitioners have
with pharmaceutical companies
and medical device companiesand their distributors.
(03:40):
The quick explanation forhow the program works is
that drug and device makers are
required to keep track of payments
and other transfers of value they make
to certain healthcare providers
during the course of each calendar year.
Then in the beginning ofthe following calendar year,
(04:01):
they're required to reportthis information to CMS
via the Open Payments database.
CMS collects the information,
runs validation checks,
and ultimately releases the data publicly
on a public website
where anyone can access it, search it,
(04:21):
look up various companies,healthcare providers,
teaching hospitals to see
what these financialinteractions look like.
- That's really interesting, Veronika.
So how long has this program been around
and how long have nurse practitioners been
included in the data reporting?
- The program was created
(04:42):
by the Physician PaymentSunshine Act of 2010
with these requirementsgoing into effect in 2013,
but it is still fairly newfor nurse practitioners.
When the program first started,
it only included payments made
to physicians in teaching hospitals.
(05:03):
The Support Act of 2018 thenexpanded the program to include
additional providertypes starting in 2021.
These additional provider types were
nurse practitioners,
clinical nurse specialist,
certified registered nurse anesthetists,
anesthesiologist assistants,
(05:25):
certified nurse midwives,
and physician assistants.
- Thank you for providingthat background, Veronika.
So why exactly was Open Paymentscreated in the first place?
- Well, the statutory intentbehind Open Payments is
to bring to light thesefinancial relationships
(05:45):
that may give rise tofinancial conflicts of interest
and bias providers' clinical judgements,
while also acknowledging that receiving
some transfers of valuefrom the industry is
normal and commonplace
and often is of ultimatebenefit to the patients
(06:06):
as collaborations betweenindustry and clinicians can
help make new discoveriesand advance medicine.
Making the data about whathealthcare providers are
paid by pharmaceutical andmedical device makers public
empowers the patients and advocates
(06:27):
with additional points information
when making decisionsabout their healthcare.
It is also important to note
that in administering theOpen Payments program,
CMS acts as a neutral intermediary,
collecting the data from the industry,
again, running various validations, checks
(06:48):
to make sure the data is accurate
and then releasing it to the public.
CMS makes no interpretationsor determination
as to whether any particularreported transaction is
good or bad.
The interpretation of data is
always up to the consumers
within their individual context
(07:11):
and healthcare decisionsthey need to make.
For example, the data can help them decide
whether to get a second opinion
or ask their providerabout generic alternatives
or maybe to choose a new provider.
- Thank you so much for providing
the history of the program, Veronika.
That provides great context tounderstanding Open Payments.
(07:32):
And with a lot of healthcare programs,
there's a lot of different terminology
that Open Payments uses
that individuals may be unfamiliar with.
So do you mind telling usabout some of the terms
that Open Payments usesand what they all mean?
- Of course.
So the most common terms are
covered recipients and reporting entities.
(07:53):
So covered recipients refer
to the healthcare providers who are
reportable in Open Payments.
So collectively, they include
physicians, teaching hospitals
and the additional provider types
that were added by the Support Act,
the nurse practitioners,physician assistants, and so on.
(08:14):
So covered recipients refers
to the providers becausethey receive the payments,
they're covered recipients.
Another term is reporting entities,
which report the data.
So those are pharmaceuticaland medical device
manufacturers and distributors.
(08:36):
Another common term in the program is
group purchasing organization or GPO.
So they are also a reporting entity
and type of reporting entitythat is a distributor.
Another common term isnon-physician practitioners.
That is a term we use in the program
(08:57):
to collectively refer
to these additional provider types
that were added in 2021,
which includes nursepractitioners as well.
- Thank you so much forclarifying that terminology.
That's really helpful tounderstanding the program.
So now let's dig intothe data a little bit.
(09:17):
What exactly is in the data
that's reported to CMS
and how much is disclosedvia Open Payments?
- There are three broad types
of financial relationships
that are reported to Open Payments.
They are general research and ownership.
General payments or transfers of value are
(09:38):
for things like food and beverage,
travel gifts,
honoraria, speakingengagements, just to name a few,
and those are payments
that are not made
in relation to a formalresearch agreement or protocol.
The general payment category is
(10:00):
consistently the largest one
by volume of transactionsthat are reported,
but most individual payment amounts
in that category are pretty small.
So the most common item inthe general payment type is
the food and beverage,
followed by travel and lodging.
(10:22):
The second category isthe research payments,
research-related paymentsor transfers of value
that are made for different types
of research activities
that are connected
to a formal researchagreement and protocol.
Research payment categoryis smaller by volume
than general payments,
but leads each year,
(10:44):
year-over-year with thehighest total dollar value
in payments that are reported.
And typical individual payment amounts are
much larger than general payments.
Research payments can include
those that are made directlyto the covered recipient
and it also includes what we call
(11:07):
associated research payments.
These are transactions that are made
in relation to research
on which the covered recipient served
as a primary investigator
but may not have been a directrecipient of those funds.
It's an importantdistinction to keep in mind
(11:28):
because while looking at and interpreting
our research payments data,
if you see that indicator
for associated research payments checked,
that just means that the covered recipient
for whom it has been reported
may not have actually receivedany money from that transfer.
(11:50):
Another important noteabout research payments is
that the statute permits
the reporting entities to request
a delay to the publication
of some of these recordsfor up to four years.
And this is done to protect
the companies from any negativecompetitive implications,
if a payment inadvertently reveals
(12:13):
sensitive or proprietaryinformation, for example.
And our third type ofOpen Payments report is
what is known as physician ownership
and investment interests.
These reports include
values of investments
or ownership stakes that physicians
(12:34):
or their immediate family members hold
in the reporting entities.
And this requirement only applies
to physicians or theirimmediate family members
and only is reportable
by non-publicly traded companies.
So it's the smallest category for us,
(12:55):
both number of recordsand total value-wise,
and it is not applicablefor nurse practitioners.
Also, the list of specificdata elements collected is
different for each ofthe above payment types,
but it can include
(13:15):
things like the total amount of payment,
the date it was made,
what form it was made in,
what was the specificcontext of the payment,
for example, research study or conference,
whether it was made
in relation to anyspecific covered product
or covered products anddetails about such products.
(13:40):
As to the part of the question
of how much is disclosed,
I think Amy has
some good numbers for us.
- Well, we reallyappreciate that Veronika,
and I think as you were mentioningsome of those categories,
it's really importantfor listeners to start
thinking through their day to day
(14:01):
and how they interact withthose types of payments
and transfers of value.
And so thank you forteeing off Amy as well
because it would be great, Amy,
if you could give ussome of the background
on the program and what has the data shown
CMS that you've learnedthrough these years?
- Yeah, absolutely.
So in the latest data publication,
we published a totalof 16 million records,
(14:23):
and that came to a totalof $13 billion in payments
or transfers of value that were made.
So some of the highlights are
that there were about 1,800companies reporting records.
So those are the reportingentities that Veronika mentioned.
So, about 1,800 of those.
And then as far as the coveredrecipients receiving data,
(14:47):
there are nearly 652,000physicians in the data
and 338,000 non-physician practitioners.
Now, to piggyback offof what Veronika said,
the non-physicianpractitioner category includes
all of those provider typesthat were added in 2021,
(15:08):
but if we break it down,
nurse practitioners make up
about 70% of that 338,000 number,
and then there are
1,288 teaching hospitals
that have records attributed to them.
Also, when we look atthe payment categories,
(15:29):
there were 15 milliongeneral payment records
and that came to $3.33 billion.
And the research payment category has
about 756,000 records,
making up eight and a halfbillion dollars of the data.
(15:50):
- I mean, 16 million records,
that is a ton of data to have reported
and for CMS to collect.
So how exactly does theagency go about doing that?
- Yeah, it is a lot of data.
We have a yearly cycle thatthe program operates on,
so really there's alwayssomething happening
with the program.
So the four key timeframes is
(16:11):
data collection, data submission,
then we have a pre-publicationreview and dispute period,
and then finally the data publication,
where it's released on our public website.
So each year from January1st through December 31st,
the reporting entities are
keeping track of their reportable data.
So those are the paymentsor transfers of value
(16:33):
that they're making tothe covered recipients.
So for the purpose ofour conversation today,
we'll use the programyear 2024 as our example.
So from January 1st, 2024
through December 31st, 2024,
the reporting entities were
tracking what data theywould be reporting.
(16:53):
Then on February 1st in 2025,
so following that fulldata collection period,
the data submission period opened
and reporting entitiessubmitted their data
through the CMS Open Payment system,
and then this reporting period closed
on March 31st.
(17:14):
After the data submission period closes is
what we call the pre-publicationreview and dispute period.
This period runs annually fromApril 1st through May 15th.
It's the opportunityfor covered recipients,
including nurse practitioners,
to review any data that'sbeen submitted about them
before it's published on the website.
(17:35):
So covered recipients can
review the data andaffirm that it's correct,
or if they believe anything is
reported incorrect or incomplete
or is inaccurate in anyway for that matter,
they can dispute it.
If they dispute the data,
they'll work directlywith the reporting entity
to reach a resolution beforethe data is published.
(17:57):
The reporting entities have
until May 30th every year to resolve
the disputes for the resolutionto appear in the data.
Records with disputes
which the resolution isn'treached by that deadline will
still be included in the data,
but we make sure that there's a flag
to note that the data was disputed.
(18:18):
And then finally afterthe data submission,
the review and dispute period,
we get to the big day,
which is the data publication,
and we are required to publish the data
by June 30th each year.
So that deadline is statutorily imposed
in the day that we track
towards each year for publishing the data.
(18:41):
- And we really appreciate that background
on the yearly cycle.
And I know on AANP's part,
we try to send out information
to our members thatcorresponds to those key dates
so that they can make sure
that they're participatingand engaged with the program.
So now moving on to someadditional questions.
We've had the benefitof presenting with you
at a conference before
(19:02):
and got some interesting questions.
So wanna turn to some of the questions
that we have received aboutthe Open Payments program.
So to turn back to Veronika,
Veronika, why should Open Payments matter
to nurse practitioners?
- Sure, Frank.
Open Payments mattersto nurse practitioners
because they are of course
one of the covered recipient types
(19:23):
that are reportable in Open Payments.
And also because the datareported about them is
data that their patients may see
and want to talk about.
And it may include
items that nurse practitioners
may not even be aware ofas being publicly disclosed
(19:44):
because remember, the information that is
reportable in Open Payments includes
monetary payments,
but also other transfer,
so value which may be non-monetary
and can include value of in-kind items
such as meals or gifts provided,
(20:05):
as well as various non tangibles
such as cost of airfare
or event admission fees
that were paid by the companyon behalf of the provider.
Also, it's important to note
that while CMS emphasizes
that receiving payments
(20:26):
or other transfers of value
from companies doesnot automatically imply
any wrongdoing or unethical behavior
on the part of the provider,
it may still be the case
that some perfectly innocuous payments may
give an impression of whatwe call in the government
(20:46):
an appearance of impropriety
when they're seen by the patients.
So it's important fornurse practitioners to know
what's being reported about them
so they're not caught off guard
if a patient asks about something
that they saw on theOpen Payments database
or possibly in a media publication
(21:09):
that used Open Payments data.
And of course if somethingis reported in error
or if it's improperly contextualized
that may cause reputationaldamage to the provider,
it is important to know about that
and take action duringthe pre-publication review
(21:30):
and dispute period that Amy discussed
during which the providers can see
the data that was reported about them
before it becomes public
and have the option oftaking this dispute action
with the applicable manufacturer
who reported the payment
if they see something that is
inaccurate or misleading, for example.
(21:54):
It also matters
because on the flip side,
embracing transparencythat Open Payments seeks
to provide can create
valuable opportunities to build
or enhance your patient's trust.
Whether you receive anyreportable payments or not,
(22:14):
letting your patientsknow about Open Payments
and being ready and willing to have
an open and non-defensive dialogue
about anything they may have seen reported
can reassure them thatyou are both mindful of
and take seriously theethical concerns that arise
(22:35):
from financial conflicts of interest,
either actual or perceived.
Last but not least,
reviewing your Open Payments records can
also serve introspective purposes.
Looking back at whatdirect or indirect payments
or other transfers of value you receive
(22:58):
during the previous year can
let you question if you may be
influenced by some unconscious biases
that are
unconscious and whether that bias may
sadly affect what you prescribe
or recommend to patients.
(23:18):
There is substantialbody of research evidence
that receipt of financialpayments from industry is
consistently associated
with increased prescribing
and that even small payments may
measurably influence provider's behavior.
So with that, it may be worth
(23:39):
a few moments of reflection
on whether maybe, just maybe,
this t-shirt or book
or complimentary journalsubscription you received
from a company has made you
just a little bit more likely
to think of that company's products
just a little bit more readily
(24:00):
than other equally effective options
that may be availablein any given situation.
- Thank you, Veronika.
And so how do providers know
exactly what can be reported about them
and are there any certain dollar amounts
that would need to be reported?
- Yeah, this is a great question, Frank,
(24:20):
and really good information
for everyone involvedin the program to know.
So we have annual reporting thresholds
or de minimis amounts.
The original threshold in the statute was
$10 for a single payment
and $100 for aggregateper provider per year.
But we actually adjust theseamounts annually for inflation.
(24:43):
So for calendar year 2025,
which is the data that is currently being
collected and reportingentities are keeping track of,
the thresholds are $13.46for single payments
and $134.54 for aggregate amounts.
So what this means is
(25:03):
that any individual paymentor transfer of value
that is $13.46 or greater
would have to be reported.
It also means that ifmultiple payments were
made to a provider
and collectively totaledmore than $134.54,
all individual payments included
in that aggregated total
(25:25):
would need to be reported
even if some of thoseindividual payments were
less than that $13.46 total.
So I know that that's a lot,
a lot of different numbers.
So here's some examples that will
hopefully elaborate
on how this annualreporting actually works.
(25:46):
So let's say that there's
a single payment threshold of the $13.46,
and company A brings a mealto a nurse practitioner.
It's only one meal,
and there were no other transactions
between that company and thenurse practitioner that year,
and that singular meal was priced at $13.
(26:09):
That would mean thatparticular transaction
would not have to be reported.
But let's say company A brought
that same nurse practitioner a meal
that was a value of $15,
then it would be over thesingle payment threshold
of $13.46
and would in turn be reportable.
(26:31):
Now for the aggregate threshold,
say a certain pharmaceuticalrepresentative meets
with you once a month,
every month for a year,
and each time you meet,
he presents you with a$10 coffee gift card.
At the end of the year,
you've received 12individual transfers of value
of $10 each,
(26:52):
which collectively come to $120.
In this situation,
the individual payments are
under that single payment threshold
and their total is underthe aggregate threshold.
So assuming that there were
no other payments or transfers of value,
these gift cards would not be reportable.
(27:14):
However, if the gift cards were say
$12 instead of 10,
your end of year total would be $144,
which would then make it
above the aggregate threshold of $134.54,
which results in all 12cards being reported.
(27:36):
Hopefully that helps break it down.
We do publish the annualreporting thresholds
on our website,
so covered recipients canlook at those every year
and be aware of those values
and what could be reported on them.
- Those are really helpful examples, Amy.
So in addition to meals and gift cards,
what are some other commonexamples of payments
(27:57):
or transfers of value thatare reported to Open Payments?
- Sure, it can be a variety of things,
tangible or intangible,
basically almost anythingthat is of monetary value.
Some examples would include
paid travel costs,
compensation for consulting
(28:20):
or other non-consulting services,
cost of professionalpublication subscription,
paid or waived event fees,
stock certificates
or even charitable contributions made
on the provider's behalfcan be reportable.
Examples are really close to infinite,
(28:40):
so it may be a little more helpful
to first take a look at howvarious types of transactions
could show up in the data.
Let's start with research payments.
For research payments,
each reported transaction is
categorized according toits expenditure category
(29:02):
and its form of payment
or transfer of value.
Expenditure categories include
professional salary support,
medical research,
writing or publication,
patient care, non-patient care,
overhead and other.
Forms of payment or transfers of value can
(29:25):
include things likecash or cash equivalent,
in-kind items and services,
stock, stock options,
any other ownership interest,
dividend, profit,
or other return on investment.
So to put it into an example,
let's say you are assistingon a research study
(29:47):
sponsored by a pharmaceutical company
that is an Open Payments reporting entity,
and say this company gives you
with a digital stethoscopeto use in the study
and then keep.
Something like this could show up
in the patient care expenditure category
(30:08):
and in-kind items andservices form of payment.
For non-research related,
general payment reports,
transactions are categorized
according to also their form of payment,
which is the same as whatwe just talked about,
(30:31):
in-kind items or services,
cash or cash equivalent,
stock and so forth.
But unlike research for general payments,
we also use
natures of payment category,
and the entire list ofoptions is pretty long,
but some of the most common ones are
(30:54):
you know, of course food and beverage
by far is the mostcommon in that category.
Travel and lodging is the second highest.
Consulting fees,
compensation for serving as faculty
or speaker at an event,
entertainment, education andso forth are other examples.
(31:17):
And the full list of thesepayments categories is
of course available on our website
on the Natures of Payment page.
- Thank you, Veronika,
could you share some examples with us?
- Sure, some examples here could be
let's say a company representative
(31:38):
asking you to complete
a questionnaire about your experience,
opinion, recommendationabout their products,
and let's say they compensate you
for your time with a $200 Visa card.
Something like this can be
reported in the honorarianature of payment
(32:01):
and cash or cashequivalent form of payment.
Or for example, an invitation to attend
an educational seminar in another state
that is sponsored by acompany with expenses paid,
an engagement like thiscould actually create
(32:21):
multiple reportable transactions
with different natures of payment.
So for example,
costs of travel could be reported
in the travel and lodgingnature of payment,
the cost of seminar admission
that a general attendeewithout a special invitation
(32:42):
would be paying could bereported as education,
a nature of payment.
And let's say, yeah, there are
complimentary meals thatare served during the event.
So all of those, of course, could be
reported as food andbeverage nature of payment.
- So with all of thatdata that can be reported,
(33:03):
what if something is not accurate?
Can nurse practitioners review
the data before it's published?
- Yeah, so great question.
That's what we really put
an emphasis on for the covered recipients,
is for them to know
that they can review the data,
especially before it comesout on the public website.
So we have a 45-day period
(33:25):
ahead of the data publication
where nurse practitioners
and any covered recipientfor that matter are
encouraged to review data
submitted about themto verify it's accurate
before it is published.
We refer to this as thepre-publication review
and dispute period,
and it takes place every year
from April 1st to May 15th.
(33:46):
So those are reallyimportant dates to note down.
Review and disputeactivities do take place
within the Open Payments system,
which is a secure online portal,
and it does require registration.
Within the system, thenurse practitioners can
view data that's been reported about them,
and if it's correct,
(34:06):
they have the option to click Affirm
to note that they agree with the data
that's being reported about them,
or if it's incorrect,
that they can initiatea dispute on the record
and they work directlywith a reporting entity
to reach a resolution.
So one thing that's reallyimportant to note is
that nurse practitioners can
(34:27):
register in the Open Payments system
to see anything reported aboutthem before it's published.
So registration is required
if you wanna reviewanything before it comes out
on the public website.
To access our system,
it's available atopenpayments.system.cms.gov,
(34:49):
and the registration processtakes about 15 minutes.
It's pretty straightforward, though.
We do have a lot of resources
on our general informationalOpen Payments website.
I'm gonna give another link here,
cms.gov/openpayments.
We have lots of resourcesabout how to complete
(35:10):
the registration,
including a video tutorial
and a registration checklist
to make sure you have allof your information together
before you start registering.
So I highly recommend looking
at the checklist and pulling up the video
if you're gonna do theregistration process,
because those two are super helpful.
And like I said, theregistration process is
(35:31):
very straightforward,
but those are greatresources to have on hand.
And then the system accesspoint one more time for you is
openpayments.system.cms.gov.
Also, just a little note here
for nurse practitioners who might be
working in a teaching hospital,
(35:53):
when you register in theOpen Payments system,
make sure you register yourself
as a non-physician practitioner.
Do not select the register asa teaching hospital option.
That is specificallyfor teaching hospitals,
not those working in a teaching hospital.
So teaching hospitals are
also covered recipients underthe Open Payments program,
(36:15):
and they have to create
their own profile for their organizations.
Again, the pre-publicationreview and dispute is
each year from April 1st to May 15th.
We also like to notethat CMS does not mediate
the disputes between covered recipients
and reporting entities.
So it's up to the covered recipient,
(36:37):
in this case, the nurse practitioners,
to work directly with the reporting entity
to reach a dispute resolution.
- So Amy, what happens
if a dispute isn't resolved by May 15th?
- So if a dispute isn't resolved
by that May 15th date,
the reporting entities have
(36:57):
an additional 15 days to resolveany outstanding disputes.
So they have until May 30th of each year.
But if a dispute isn'treached by that time,
the record will be publishedand marked as disputed,
which notes in the public data
that the covered recipient does not concur
with the reported payment.
(37:19):
So a couple actions that can be taken
when reviewing therecords in the system is
affirming that the data is correct,
disputing data that the nurse practitioner
doesn't agree with,
and they can also withdraw a dispute
if they find that it'sno longer necessary.
(37:40):
- So Amy, how prevalent are disputes?
- So disputes are very low.
We don't see a lot year to year.
And just to give a little perspective,
in calendar year 2024,
there were less than1,000 covered recipients
that initiated disputes.
(38:00):
We do know that the highestnumber of disputes is
typically for the entertainmentnature of payment category,
but again, overall thedisputes are very low.
- And what are the ways
that disputes are ultimately resolved?
- Sure, so there are two ways
in which disputes can be resolved,
(38:21):
which is resolved orresolved with no change.
They're the two disputestatuses that you can see
in the system.
Resolved status indicate
that the reporting entity andthe covered recipient reached
a resolution,
and that resolution resultedin an update to the record.
(38:44):
Resolved with no change status means
that the resolution was reached,
but there was no change tothe record made as a result.
So this is often the case
when the covered recipient, for example,
didn't remember receiving
the payment or transfer value
(39:05):
or didn't quite understandwhat it was for,
but the reporting entitywas able to explain
to the covered recipient and confirm
that the transfer of value did occur
and that it was reported correctly.
So in this situation,
the reporting entity can mark
(39:25):
the dispute as resolved
without making any change tothe information on record.
And of course, there isalso the option to withdraw
dispute by the covered recipient.
So occasionally, that happensin a similar situation
when the recipient didn't quite understand
what the payment was for,
but they were able toreach out to the company
(39:48):
outside of the Open Paymentssystem and get the explanation,
and they decided to no longer dispute
that record and withdraw the dispute.
- Could you provide us with an example
so that we can pull all ofthis information together?
- Absolutely, it is a lot of information.
(40:09):
So, I know examples are very helpful.
I'll preface this by saying
that all the names and scenarios
in this sample case study
that we're gonna shareare completely fictional,
so any likeness to individualsis completely coincidental.
So with that being said,
let's talk about a nurse practitioner
(40:29):
who just learned about Open Payments,
and we'll call her Lauren.
So Lauren is reallyfamiliar with interacting
with drug and medicaldevice representatives
in her weekly activities.
Let's say that often a drugrep from Company X brings
her lunch and educates her on medicine
that she could beprescribing to her patients.
(40:49):
In addition to these lunches,
she also accepted an invitation to speak
at Company X's conference
where the company paid
for all of her travel and compensated her
for the presentation that she delivered
at the conference as well.
Well, now that Laurenknows about Open Payments,
she wants to make sure that everything was
(41:09):
recorded accurately
and that there is no incorrect information
on her Open Payments profile.
So Lauren registers inthe Open Payments system
as a non-physician practitioner,
and on April 1st she logs in to review
the data that was submitted about her.
She sees a total of 10food and beverage records
(41:30):
that come to a total of $205,
a travel and lodging record for $1,000,
and a speaking engagement record for $100.
All of this accounts fora total of 12 records
that come to $1,305.
(41:50):
Of those records,
of the 10 food and beverage payments,
Lauren recognizes eight payments,
but knows that one of thefood and beverage records does
not belong to her
because she was actually on vacation
on the date of the payment
and another food andbeverage record for $25
doesn't look correct.
So she initiates a disputeon these two records.
(42:12):
Company X then acknowledges the dispute
and reaches out to Lauren
to come to a resolution.
For the first disputed record,
it's determined that Lauren is correct
and she's not the provider
this payment should be attributed to.
So Company X resolves the dispute
by updating the coveredrecipient information
so it is not associatedwith Lauren anymore.
(42:36):
When Lauren logs into theOpen Payments system again,
she doesn't see the disputedpayment record at all
because it has beenremoved from her profile
and is associated withthe correct provider.
The other disputed record is
determined to, in fact, belong to Lauren,
but Company X sees thatthe total should have been
for $20 and not 25.
(42:57):
So they resolve the dispute
by correcting the total to $20.
Lauren will now see that dispute
as resolved with change
when she logs back in.
She reviews the updated record
and then affirms that it's correct
because the change was made correctly.
- That's a great example, Amy,
but what happens if aclinician doesn't review
(43:19):
the data during the pre-publication review
and dispute period?
For example, the 2024data was just published.
So what if a covered recipient
didn't know to review the data
during the prior periodand wants to do it now?
- Yeah, so this is actuallya pretty common scenario
as people learn about the program.
So we do put a lot of emphasis
(43:40):
on the pre-publicationreview and dispute period
because of it giving ample opportunity
for review of the databefore it's published.
But if someone missedthis review timeline,
they shouldn't worry becausethey can still review
their data.
So the Open Payments datais available for review
within the Open Payments system
through the end of the calendar year.
(44:00):
So, covered recipients have
until the end of each calendaryear to review, affirm
or if needed initiate disputes on data
in the Open Payments systemas we previously discussed.
So the Open Payments team refreshes
the published data in January every year,
which means that any dispute activities,
(44:21):
including data corrections that are made
between now and the end of the year
will be reflected in the data refresh.
So it's important to note
that after December 31st,
the Open Payments systemwill not display records
that were published this year for review.
So nurse practitionerswould be able to see them
on the public-facing site,
but records are only availablein the Open Payments systems
(44:44):
throughout the calendar year
in which they were first published.
So if you missed thereview and dispute deadline
and you wanna review this year's data
within the system sothat you can affirm it
or if needed dispute it,
you'll wanna keep the December31st deadline in mind.
- Yes, Amy and I just wanted to add
(45:06):
that we understand
that the program can seem complex,
and it's a lot of numbers and timelines
and terminology that we just shared,
but we really want the providers to know
that it's actually prettyeasy to review the data.
And while there are many scenarios
(45:28):
that we could discuss
about the timing of whensomeone reviews the data,
the bottom line, it'simportant to review it
even if just for your own sake
of knowing if anythingis reported about you.
So if you missed the reviewand dispute deadline this year,
(45:50):
no worries.
You still have time
and should take the time
to log in to the Open Payments system
and see if there are any recordsthat are attributed to you,
which can also include
those delayed research recordswe talked earlier about,
something that you wouldn't see
necessarily in the public data yet,
(46:12):
but that can still be
non-public in the Open Payments system.
Lastly, I wanted to note
that if you see older data
published on the website
that isn't correct
or that you think is misleading
and should be better contextualized,
(46:33):
but the data isn't available for action
and in the Open Payments system anymore
because it's passed theend of the calendar year
when it was first published,
you can still reach out directly
to the reporting entity
and work with them to get it corrected.
(46:53):
Reporting entities do have
the ability to resubmit the data,
even if it's from a prior calendar year.
So it is still possible
that older data can be corrected too,
but you may need to reach out
to the reporting entity who submitted it
outside of the Open Payments system.
(47:16):
- Thank you both for weighing in on that.
And other than registering
for Open Payments and participating
in the review and dispute process,
which we really encouragenurse practitioners to do,
what other proactive steps are there
that NPs should take in regards
to the Open Payments program?
- Thanks, Frank.
It's really importantfor nurse practitioners
(47:37):
to just have a generalawareness about the program,
including knowing what can be reported
and be prepared in case patients inquire
about the Open Payments data.
I'll just put another plug in
for those annual thresholds
since those do change annually,
that's a good thing.
Once people are aware of the program
and know that things couldbe reported about them,
(47:58):
to keep in mind those dollarthresholds that are reportable.
And of course, reviewingdata every year is crucial.
That way, nurse practitioners know
what data has been attributed to them
and that the data is accurate.
This also helps them know
what's going to be publicly available
so there aren't any surprises.
(48:20):
If you have or expect to havesome data reported about you,
it's important to think aboutwhat questions patients might
ask if they see it
and think through some talking points
that you could respond with.
- Yeah, and I would also add
consider proactivelysharing about Open Payments
and again, using it as opportunity
(48:41):
to build trust with your patients.
For example, in California,
it has now been a state law
for physicians to discloseOpen Payments to patients.
Providers in other states may choose to do
the same on a voluntary basis.
As discussed earlier,
being open about Open Payments is
(49:02):
a good faith gesture that can help enhance
relationship with a patient.
So, do consider sharingwith your patients about it,
maybe via a handout or somekind of notice in the office
to create an open door policy to have
the dialogue about anythingyour patients may have seen.
(49:27):
- This is great, great information
that both of you have provided today.
So how can NPs stay informed
about the Open Payments program
and where can they find all the resources
that you've mentioned?
- We'd love for everyone to stay informed
about the program and use our resources.
We're very happy witheverything that we provide.
And I'll also say thank you here
(49:49):
to the American Associationof Nurse Practitioners
because I know, Frank, thatyou guys help us so much
with sharing our information
and reminding everybodyabout the review and dispute
every year and all of those key deadlines.
But a couple of things to note,
we do have a listserv thatpeople can subscribe to.
So if you visit ourcms.gov/openpayments page,
(50:13):
if you click Contact Us,
there's a box that you can sign up.
Our listserv is our number one way
to get information out about the program.
So that's really thebest way to stay in touch
with the program, hear the announcements.
Of course, we always announcewhen the data's published.
We send reminders of thereview and dispute period
(50:34):
and anything else that'sgoing on throughout the year.
So that is a really keyresource, is the listserv.
A few other things to note is
the Open Payments database.
So if you wanna see wherethe data is published
and the live searchable data,
that's available atopenpaymentsdata.cms.gov.
(50:55):
And as previously mentioned,
we have our general website,
which is cms.gov/openpayments.
This is the main website
for covered recipient resources,
which includes an Open Payments user guide
and other downloadable content.
It also has links to our videos
and that registration quick start guide
(51:17):
that I mentioned earlier,that's on this webpage.
So jot that down and bookmark it
because it will be your bestfriend for program resources.
And then we do have avariety of video tutorials,
including the registration video tutorial,
and a video tutorialthat walks you through
the review and dispute process.
(51:38):
So like Veronika said earlier,
we know there's a lot ofdetails to the program,
but we try to simplify it
and make it very easy
because it is easy and straightforward.
- Well, Veronika and Amy,
we really appreciate all of the work
that you and your teams doin creating those resources.
And thank you again for joining
the "NP Pulse" podcast to inform
(52:00):
nurse practitioners aboutthe Open Payments program.
Your team have been great partners
in providing education on the program,
and we encourage nursepractitioners to enroll
in the program to be able to review
and dispute your data
and go to the OpenPayments website to review
all of those resourcesthat Amy just mentioned.
AANP is also passing along these resources
and other important updates to members
(52:21):
in our weekly government affairs update.
So please make sure to check that out
when we send it out every Monday.
And Veronika and Amy,
I will turn it over to you
for any last items you'd like to mention.
- Thank you so much, Frank,and AANP team for having us.
It has been great to be here with you
and have this opportunityto share about the program.
(52:43):
One closing thought I want to share,
something we didn't talk much about
but a question that often comes up,
something that the patientsmay definitely ask about,
well, how accurate is the data?
Can we trust the data in the database?
So I just wanted to note
that we do put great care into ensuring
(53:05):
the accuracy of data,
both on entry and in compliance review
and through follow-upwith reporting entities.
So since that didn't come up
much in our conversation earlier,
that's one closing point Idefinitely wanted to make,
that we do believe
the data to be pretty accurate
(53:26):
and we take great careto ensure that it is.
- Yeah, and I'll just say thank you again.
This has been an awesome opportunity.
We really appreciate the partnership
and the opportunity to share
the information about the program,
so thank you so much for having us.
- Well, it's been ourpleasure, Veronika and Amy.
(53:46):
So thank you again for joining us,
and we'll make sure to be on the lookout
for all those greatOpen Payments resources
so that we can send themover to nurse practitioners
so that they can stayinformed about the program.
Have a wonderful day.
- Thank you so much.- Thank you.
(upbeat music)
- Well, thank you so much,Amy, Veronika and Frank.
(54:07):
It's been an absolute pleasure
listening to you and gainingyour perspective and insights
on this extremely important topic.
To our listeners, I hope youfound this episode educational
and can apply some of what wasdiscussed to your practice.
Join your NationalProfessional Association
and add your voice to over 120,000
of your NP colleagues nationwide.
(54:29):
I urge you to become an AANP member today.
Membership gives youaccess to so many benefits,
including tools andresources for your practice
and the AANP CE Center,
which offers a comprehensivelibrary of CE activities
for NPs of all specialtiesand experience levels.
Exclusive discounts and manyfree activities are yours
(54:51):
as an AANP member to help you complete
state licensure requirements
and earn the creditsneeded for recertification.
Remember, you may claimCE credit for this program
through August, 2026
by logging in to the CE center
at aanp.org/cecenter.
Register for this program.
(55:13):
Enter the participation code OP2526.
Again, that's OP2526,
and then complete thepost-test and evaluation.
Be sure to subscribe to this podcast,
share with your colleagues
and check back often for new episodes.
Thank you for listening.
(55:33):
(upbeat music)
(upbeat music)
- From the American Associationof Nurse Practitioners
I'm the host of today'sspecial edition episode,
nurse practitioner and educationspecialist Patty Scalzo,
(00:22):
and this is "NP Pulse", thevoice of the nurse practitioner.
(upbeat music continues)
Welcome to "NP Pulse",AANP's podcast bringing you
unique nurse practitioner voices
and expertise on issues that matter
to NPs and our patients.
(00:44):
As always, be sure tosubscribe to this podcast,
share with your colleagues,
and check back often for new conversations
with nurse practitionersand healthcare leaders
from across the nation.
"NP Pulse" podcast listeners may claim
CE credit for this programthrough August, 2026.
After you listen to the podcast,
visit aanp.org/cecenter,
(01:08):
register for this activity,
enter the participation code provided
at the end of the podcast,
and then complete thepost-test and evaluation.
On today's episode, we will be exploring
the Open Payments program,
a key element of professional practice
for nurse practitioners.
This national initiative promotes
transparency by publicly reporting
(01:30):
financial relationshipsbetween healthcare providers
and pharmaceutical ormedical device companies.
Whether it's consulting fees,
research payments, or even meals,
these interactions are recorded
in a searchable database open to anyone.
Understanding what's reported about you is
essential for maintaining trust,
(01:50):
ensuring accuracy,
and upholding ethical standards.
Let's take a closer lookat how the program works
and what it means for your practice.
Frank Harrington,
the Director of Reimbursementand Regulatory Affairs
at AANP will be moderatinga lively discussion
with members of theCMS Open Payments team,
Amy Bedsaul and VeronikaPeleshchuk Fradlin.
(02:13):
It is my pleasure to welcomethis panel of experts.
- Welcome to "Open Paymentsand the Nurse Practitioner,
Your Role in the TransparentHealthcare System".
Today we are excited to welcome
members of the CMS Open Payments team
who will share information and updates
about the program with you.
I'm Frank Harrington,
AANP's Director of Reimbursementand Regulatory Affairs,
(02:36):
and I would like you to meetour guests, Veronika and Amy.
Veronika, would youplease introduce yourself?
- Hi, Frank.
I'm Veronika Peleshchuk Fradlin,
Director of theTransparency and Data Group
at CMS Office of HealthcareExperience and Interoperability,
and it's great to be here.
Thanks so much for having us.
(02:57):
- Thank you so much forbeing here today, Veronika.
And Amy, would you pleaseintroduce yourself?
- Hi, I'm Amy Bedsaul.
I do the Open Paymentscommunications activities.
It's just great to behere with everyone today.
We're excited to shareinformation about the program.
- Thank you so much, Amy.
And so Veronika, we would love to hear
about the background of the program.
(03:18):
So what exactly is theOpen Payments program?
- Sure.
Open Payments is anational disclosure program
that provides transparencyinto financial relationships,
healthcare providers suchas nurse practitioners have
with pharmaceutical companies
and medical device companiesand their distributors.
(03:40):
The quick explanation forhow the program works is
that drug and device makers are
required to keep track of payments
and other transfers of value they make
to certain healthcare providers
during the course of each calendar year.
Then in the beginning ofthe following calendar year,
(04:01):
they're required to reportthis information to CMS
via the Open Payments database.
CMS collects the information,
runs validation checks,
and ultimately releases the data publicly
on a public website
where anyone can access it, search it,
(04:21):
look up various companies,healthcare providers,
teaching hospitals to see
what these financialinteractions look like.
- That's really interesting, Veronika.
So how long has this program been around
and how long have nurse practitioners been
included in the data reporting?
- The program was created
(04:42):
by the Physician PaymentSunshine Act of 2010
with these requirementsgoing into effect in 2013,
but it is still fairly newfor nurse practitioners.
When the program first started,
it only included payments made
to physicians in teaching hospitals.
(05:03):
The Support Act of 2018 thenexpanded the program to include
additional providertypes starting in 2021.
These additional provider types were
nurse practitioners,
clinical nurse specialist,
certified registered nurse anesthetists,
anesthesiologist assistants,
(05:25):
certified nurse midwives,
and physician assistants.
- Thank you for providingthat background, Veronika.
So why exactly was Open Paymentscreated in the first place?
- Well, the statutory intentbehind Open Payments is
to bring to light thesefinancial relationships
(05:45):
that may give rise tofinancial conflicts of interest
and bias providers' clinical judgements,
while also acknowledging that receiving
some transfers of valuefrom the industry is
normal and commonplace
and often is of ultimatebenefit to the patients
(06:06):
as collaborations betweenindustry and clinicians can
help make new discoveriesand advance medicine.
Making the data about whathealthcare providers are
paid by pharmaceutical andmedical device makers public
empowers the patients and advocates
(06:27):
with additional points information
when making decisionsabout their healthcare.
It is also important to note
that in administering theOpen Payments program,
CMS acts as a neutral intermediary,
collecting the data from the industry,
again, running various validations, checks
(06:48):
to make sure the data is accurate
and then releasing it to the public.
CMS makes no interpretationsor determination
as to whether any particularreported transaction is
good or bad.
The interpretation of data is
always up to the consumers
within their individual context
(07:11):
and healthcare decisionsthey need to make.
For example, the data can help them decide
whether to get a second opinion
or ask their providerabout generic alternatives
or maybe to choose a new provider.
- Thank you so much for providing
the history of the program, Veronika.
That provides great context tounderstanding Open Payments.
(07:32):
And with a lot of healthcare programs,
there's a lot of different terminology
that Open Payments uses
that individuals may be unfamiliar with.
So do you mind telling usabout some of the terms
that Open Payments usesand what they all mean?
- Of course.
So the most common terms are
covered recipients and reporting entities.
(07:53):
So covered recipients refer
to the healthcare providers who are
reportable in Open Payments.
So collectively, they include
physicians, teaching hospitals
and the additional provider types
that were added by the Support Act,
the nurse practitioners,physician assistants, and so on.
(08:14):
So covered recipients refers
to the providers becausethey receive the payments,
they're covered recipients.
Another term is reporting entities,
which report the data.
So those are pharmaceuticaland medical device
manufacturers and distributors.
(08:36):
Another common term in the program is
group purchasing organization or GPO.
So they are also a reporting entity
and type of reporting entitythat is a distributor.
Another common term isnon-physician practitioners.
That is a term we use in the program
(08:57):
to collectively refer
to these additional provider types
that were added in 2021,
which includes nursepractitioners as well.
- Thank you so much forclarifying that terminology.
That's really helpful tounderstanding the program.
So now let's dig intothe data a little bit.
(09:17):
What exactly is in the data
that's reported to CMS
and how much is disclosedvia Open Payments?
- There are three broad types
of financial relationships
that are reported to Open Payments.
They are general research and ownership.
General payments or transfers of value are
(09:38):
for things like food and beverage,
travel gifts,
honoraria, speakingengagements, just to name a few,
and those are payments
that are not made
in relation to a formalresearch agreement or protocol.
The general payment category is
(10:00):
consistently the largest one
by volume of transactionsthat are reported,
but most individual payment amounts
in that category are pretty small.
So the most common item inthe general payment type is
the food and beverage,
followed by travel and lodging.
(10:22):
The second category isthe research payments,
research-related paymentsor transfers of value
that are made for different types
of research activities
that are connected
to a formal researchagreement and protocol.
Research payment categoryis smaller by volume
than general payments,
but leads each year,
(10:44):
year-over-year with thehighest total dollar value
in payments that are reported.
And typical individual payment amounts are
much larger than general payments.
Research payments can include
those that are made directlyto the covered recipient
and it also includes what we call
(11:07):
associated research payments.
These are transactions that are made
in relation to research
on which the covered recipient served
as a primary investigator
but may not have been a directrecipient of those funds.
It's an importantdistinction to keep in mind
(11:28):
because while looking at and interpreting
our research payments data,
if you see that indicator
for associated research payments checked,
that just means that the covered recipient
for whom it has been reported
may not have actually receivedany money from that transfer.
(11:50):
Another important noteabout research payments is
that the statute permits
the reporting entities to request
a delay to the publication
of some of these recordsfor up to four years.
And this is done to protect
the companies from any negativecompetitive implications,
if a payment inadvertently reveals
(12:13):
sensitive or proprietaryinformation, for example.
And our third type ofOpen Payments report is
what is known as physician ownership
and investment interests.
These reports include
values of investments
or ownership stakes that physicians
(12:34):
or their immediate family members hold
in the reporting entities.
And this requirement only applies
to physicians or theirimmediate family members
and only is reportable
by non-publicly traded companies.
So it's the smallest category for us,
(12:55):
both number of recordsand total value-wise,
and it is not applicablefor nurse practitioners.
Also, the list of specificdata elements collected is
different for each ofthe above payment types,
but it can include
(13:15):
things like the total amount of payment,
the date it was made,
what form it was made in,
what was the specificcontext of the payment,
for example, research study or conference,
whether it was made
in relation to anyspecific covered product
or covered products anddetails about such products.
(13:40):
As to the part of the question
of how much is disclosed,
I think Amy has
some good numbers for us.
- Well, we reallyappreciate that Veronika,
and I think as you were mentioningsome of those categories,
it's really importantfor listeners to start
thinking through their day to day
(14:01):
and how they interact withthose types of payments
and transfers of value.
And so thank you forteeing off Amy as well
because it would be great, Amy,
if you could give ussome of the background
on the program and what has the data shown
CMS that you've learnedthrough these years?
- Yeah, absolutely.
So in the latest data publication,
we published a totalof 16 million records,
(14:23):
and that came to a totalof $13 billion in payments
or transfers of value that were made.
So some of the highlights are
that there were about 1,800companies reporting records.
So those are the reportingentities that Veronika mentioned.
So, about 1,800 of those.
And then as far as the coveredrecipients receiving data,
(14:47):
there are nearly 652,000physicians in the data
and 338,000 non-physician practitioners.
Now, to piggyback offof what Veronika said,
the non-physicianpractitioner category includes
all of those provider typesthat were added in 2021,
(15:08):
but if we break it down,
nurse practitioners make up
about 70% of that 338,000 number,
and then there are
1,288 teaching hospitals
that have records attributed to them.
Also, when we look atthe payment categories,
(15:29):
there were 15 milliongeneral payment records
and that came to $3.33 billion.
And the research payment category has
about 756,000 records,
making up eight and a halfbillion dollars of the data.
(15:50):
- I mean, 16 million records,
that is a ton of data to have reported
and for CMS to collect.
So how exactly does theagency go about doing that?
- Yeah, it is a lot of data.
We have a yearly cycle thatthe program operates on,
so really there's alwayssomething happening
with the program.
So the four key timeframes is
(16:11):
data collection, data submission,
then we have a pre-publicationreview and dispute period,
and then finally the data publication,
where it's released on our public website.
So each year from January1st through December 31st,
the reporting entities are
keeping track of their reportable data.
So those are the paymentsor transfers of value
(16:33):
that they're making tothe covered recipients.
So for the purpose ofour conversation today,
we'll use the programyear 2024 as our example.
So from January 1st, 2024
through December 31st, 2024,
the reporting entities were
tracking what data theywould be reporting.
(16:53):
Then on February 1st in 2025,
so following that fulldata collection period,
the data submission period opened
and reporting entitiessubmitted their data
through the CMS Open Payment system,
and then this reporting period closed
on March 31st.
(17:14):
After the data submission period closes is
what we call the pre-publicationreview and dispute period.
This period runs annually fromApril 1st through May 15th.
It's the opportunityfor covered recipients,
including nurse practitioners,
to review any data that'sbeen submitted about them
before it's published on the website.
(17:35):
So covered recipients can
review the data andaffirm that it's correct,
or if they believe anything is
reported incorrect or incomplete
or is inaccurate in anyway for that matter,
they can dispute it.
If they dispute the data,
they'll work directlywith the reporting entity
to reach a resolution beforethe data is published.
(17:57):
The reporting entities have
until May 30th every year to resolve
the disputes for the resolutionto appear in the data.
Records with disputes
which the resolution isn'treached by that deadline will
still be included in the data,
but we make sure that there's a flag
to note that the data was disputed.
(18:18):
And then finally afterthe data submission,
the review and dispute period,
we get to the big day,
which is the data publication,
and we are required to publish the data
by June 30th each year.
So that deadline is statutorily imposed
in the day that we track
towards each year for publishing the data.
(18:41):
- And we really appreciate that background
on the yearly cycle.
And I know on AANP's part,
we try to send out information
to our members thatcorresponds to those key dates
so that they can make sure
that they're participatingand engaged with the program.
So now moving on to someadditional questions.
We've had the benefitof presenting with you
at a conference before
(19:02):
and got some interesting questions.
So wanna turn to some of the questions
that we have received aboutthe Open Payments program.
So to turn back to Veronika,
Veronika, why should Open Payments matter
to nurse practitioners?
- Sure, Frank.
Open Payments mattersto nurse practitioners
because they are of course
one of the covered recipient types
(19:23):
that are reportable in Open Payments.
And also because the datareported about them is
data that their patients may see
and want to talk about.
And it may include
items that nurse practitioners
may not even be aware ofas being publicly disclosed
(19:44):
because remember, the information that is
reportable in Open Payments includes
monetary payments,
but also other transfer,
so value which may be non-monetary
and can include value of in-kind items
such as meals or gifts provided,
(20:05):
as well as various non tangibles
such as cost of airfare
or event admission fees
that were paid by the companyon behalf of the provider.
Also, it's important to note
that while CMS emphasizes
that receiving payments
(20:26):
or other transfers of value
from companies doesnot automatically imply
any wrongdoing or unethical behavior
on the part of the provider,
it may still be the case
that some perfectly innocuous payments may
give an impression of whatwe call in the government
(20:46):
an appearance of impropriety
when they're seen by the patients.
So it's important fornurse practitioners to know
what's being reported about them
so they're not caught off guard
if a patient asks about something
that they saw on theOpen Payments database
or possibly in a media publication
(21:09):
that used Open Payments data.
And of course if somethingis reported in error
or if it's improperly contextualized
that may cause reputationaldamage to the provider,
it is important to know about that
and take action duringthe pre-publication review
(21:30):
and dispute period that Amy discussed
during which the providers can see
the data that was reported about them
before it becomes public
and have the option oftaking this dispute action
with the applicable manufacturer
who reported the payment
if they see something that is
inaccurate or misleading, for example.
(21:54):
It also matters
because on the flip side,
embracing transparencythat Open Payments seeks
to provide can create
valuable opportunities to build
or enhance your patient's trust.
Whether you receive anyreportable payments or not,
(22:14):
letting your patientsknow about Open Payments
and being ready and willing to have
an open and non-defensive dialogue
about anything they may have seen reported
can reassure them thatyou are both mindful of
and take seriously theethical concerns that arise
(22:35):
from financial conflicts of interest,
either actual or perceived.
Last but not least,
reviewing your Open Payments records can
also serve introspective purposes.
Looking back at whatdirect or indirect payments
or other transfers of value you receive
(22:58):
during the previous year can
let you question if you may be
influenced by some unconscious biases
that are
unconscious and whether that bias may
sadly affect what you prescribe
or recommend to patients.
(23:18):
There is substantialbody of research evidence
that receipt of financialpayments from industry is
consistently associated
with increased prescribing
and that even small payments may
measurably influence provider's behavior.
So with that, it may be worth
(23:39):
a few moments of reflection
on whether maybe, just maybe,
this t-shirt or book
or complimentary journalsubscription you received
from a company has made you
just a little bit more likely
to think of that company's products
just a little bit more readily
(24:00):
than other equally effective options
that may be availablein any given situation.
- Thank you, Veronika.
And so how do providers know
exactly what can be reported about them
and are there any certain dollar amounts
that would need to be reported?
- Yeah, this is a great question, Frank,
(24:20):
and really good information
for everyone involvedin the program to know.
So we have annual reporting thresholds
or de minimis amounts.
The original threshold in the statute was
$10 for a single payment
and $100 for aggregateper provider per year.
But we actually adjust theseamounts annually for inflation.
(24:43):
So for calendar year 2025,
which is the data that is currently being
collected and reportingentities are keeping track of,
the thresholds are $13.46for single payments
and $134.54 for aggregate amounts.
So what this means is
(25:03):
that any individual paymentor transfer of value
that is $13.46 or greater
would have to be reported.
It also means that ifmultiple payments were
made to a provider
and collectively totaledmore than $134.54,
all individual payments included
in that aggregated total
(25:25):
would need to be reported
even if some of thoseindividual payments were
less than that $13.46 total.
So I know that that's a lot,
a lot of different numbers.
So here's some examples that will
hopefully elaborate
on how this annualreporting actually works.
(25:46):
So let's say that there's
a single payment threshold of the $13.46,
and company A brings a mealto a nurse practitioner.
It's only one meal,
and there were no other transactions
between that company and thenurse practitioner that year,
and that singular meal was priced at $13.
(26:09):
That would mean thatparticular transaction
would not have to be reported.
But let's say company A brought
that same nurse practitioner a meal
that was a value of $15,
then it would be over thesingle payment threshold
of $13.46
and would in turn be reportable.
(26:31):
Now for the aggregate threshold,
say a certain pharmaceuticalrepresentative meets
with you once a month,
every month for a year,
and each time you meet,
he presents you with a$10 coffee gift card.
At the end of the year,
you've received 12individual transfers of value
of $10 each,
(26:52):
which collectively come to $120.
In this situation,
the individual payments are
under that single payment threshold
and their total is underthe aggregate threshold.
So assuming that there were
no other payments or transfers of value,
these gift cards would not be reportable.
(27:14):
However, if the gift cards were say
$12 instead of 10,
your end of year total would be $144,
which would then make it
above the aggregate threshold of $134.54,
which results in all 12cards being reported.
(27:36):
Hopefully that helps break it down.
We do publish the annualreporting thresholds
on our website,
so covered recipients canlook at those every year
and be aware of those values
and what could be reported on them.
- Those are really helpful examples, Amy.
So in addition to meals and gift cards,
what are some other commonexamples of payments
(27:57):
or transfers of value thatare reported to Open Payments?
- Sure, it can be a variety of things,
tangible or intangible,
basically almost anythingthat is of monetary value.
Some examples would include
paid travel costs,
compensation for consulting
(28:20):
or other non-consulting services,
cost of professionalpublication subscription,
paid or waived event fees,
stock certificates
or even charitable contributions made
on the provider's behalfcan be reportable.
Examples are really close to infinite,
(28:40):
so it may be a little more helpful
to first take a look at howvarious types of transactions
could show up in the data.
Let's start with research payments.
For research payments,
each reported transaction is
categorized according toits expenditure category
(29:02):
and its form of payment
or transfer of value.
Expenditure categories include
professional salary support,
medical research,
writing or publication,
patient care, non-patient care,
overhead and other.
Forms of payment or transfers of value can
(29:25):
include things likecash or cash equivalent,
in-kind items and services,
stock, stock options,
any other ownership interest,
dividend, profit,
or other return on investment.
So to put it into an example,
let's say you are assistingon a research study
(29:47):
sponsored by a pharmaceutical company
that is an Open Payments reporting entity,
and say this company gives you
with a digital stethoscopeto use in the study
and then keep.
Something like this could show up
in the patient care expenditure category
(30:08):
and in-kind items andservices form of payment.
For non-research related,
general payment reports,
transactions are categorized
according to also their form of payment,
which is the same as whatwe just talked about,
(30:31):
in-kind items or services,
cash or cash equivalent,
stock and so forth.
But unlike research for general payments,
we also use
natures of payment category,
and the entire list ofoptions is pretty long,
but some of the most common ones are
(30:54):
you know, of course food and beverage
by far is the mostcommon in that category.
Travel and lodging is the second highest.
Consulting fees,
compensation for serving as faculty
or speaker at an event,
entertainment, education andso forth are other examples.
(31:17):
And the full list of thesepayments categories is
of course available on our website
on the Natures of Payment page.
- Thank you, Veronika,
could you share some examples with us?
- Sure, some examples here could be
let's say a company representative
(31:38):
asking you to complete
a questionnaire about your experience,
opinion, recommendationabout their products,
and let's say they compensate you
for your time with a $200 Visa card.
Something like this can be
reported in the honorarianature of payment
(32:01):
and cash or cashequivalent form of payment.
Or for example, an invitation to attend
an educational seminar in another state
that is sponsored by acompany with expenses paid,
an engagement like thiscould actually create
(32:21):
multiple reportable transactions
with different natures of payment.
So for example,
costs of travel could be reported
in the travel and lodgingnature of payment,
the cost of seminar admission
that a general attendeewithout a special invitation
(32:42):
would be paying could bereported as education,
a nature of payment.
And let's say, yeah, there are
complimentary meals thatare served during the event.
So all of those, of course, could be
reported as food andbeverage nature of payment.
- So with all of thatdata that can be reported,
(33:03):
what if something is not accurate?
Can nurse practitioners review
the data before it's published?
- Yeah, so great question.
That's what we really put
an emphasis on for the covered recipients,
is for them to know
that they can review the data,
especially before it comesout on the public website.
So we have a 45-day period
(33:25):
ahead of the data publication
where nurse practitioners
and any covered recipientfor that matter are
encouraged to review data
submitted about themto verify it's accurate
before it is published.
We refer to this as thepre-publication review
and dispute period,
and it takes place every year
from April 1st to May 15th.
(33:46):
So those are reallyimportant dates to note down.
Review and disputeactivities do take place
within the Open Payments system,
which is a secure online portal,
and it does require registration.
Within the system, thenurse practitioners can
view data that's been reported about them,
and if it's correct,
(34:06):
they have the option to click Affirm
to note that they agree with the data
that's being reported about them,
or if it's incorrect,
that they can initiatea dispute on the record
and they work directlywith a reporting entity
to reach a resolution.
So one thing that's reallyimportant to note is
that nurse practitioners can
(34:27):
register in the Open Payments system
to see anything reported aboutthem before it's published.
So registration is required
if you wanna reviewanything before it comes out
on the public website.
To access our system,
it's available atopenpayments.system.cms.gov,
(34:49):
and the registration processtakes about 15 minutes.
It's pretty straightforward, though.
We do have a lot of resources
on our general informationalOpen Payments website.
I'm gonna give another link here,
cms.gov/openpayments.
We have lots of resourcesabout how to complete
(35:10):
the registration,
including a video tutorial
and a registration checklist
to make sure you have allof your information together
before you start registering.
So I highly recommend looking
at the checklist and pulling up the video
if you're gonna do theregistration process,
because those two are super helpful.
And like I said, theregistration process is
(35:31):
very straightforward,
but those are greatresources to have on hand.
And then the system accesspoint one more time for you is
openpayments.system.cms.gov.
Also, just a little note here
for nurse practitioners who might be
working in a teaching hospital,
(35:53):
when you register in theOpen Payments system,
make sure you register yourself
as a non-physician practitioner.
Do not select the register asa teaching hospital option.
That is specificallyfor teaching hospitals,
not those working in a teaching hospital.
So teaching hospitals are
also covered recipients underthe Open Payments program,
(36:15):
and they have to create
their own profile for their organizations.
Again, the pre-publicationreview and dispute is
each year from April 1st to May 15th.
We also like to notethat CMS does not mediate
the disputes between covered recipients
and reporting entities.
So it's up to the covered recipient,
(36:37):
in this case, the nurse practitioners,
to work directly with the reporting entity
to reach a dispute resolution.
- So Amy, what happens
if a dispute isn't resolved by May 15th?
- So if a dispute isn't resolved
by that May 15th date,
the reporting entities have
(36:57):
an additional 15 days to resolveany outstanding disputes.
So they have until May 30th of each year.
But if a dispute isn'treached by that time,
the record will be publishedand marked as disputed,
which notes in the public data
that the covered recipient does not concur
with the reported payment.
(37:19):
So a couple actions that can be taken
when reviewing therecords in the system is
affirming that the data is correct,
disputing data that the nurse practitioner
doesn't agree with,
and they can also withdraw a dispute
if they find that it'sno longer necessary.
(37:40):
- So Amy, how prevalent are disputes?
- So disputes are very low.
We don't see a lot year to year.
And just to give a little perspective,
in calendar year 2024,
there were less than1,000 covered recipients
that initiated disputes.
(38:00):
We do know that the highestnumber of disputes is
typically for the entertainmentnature of payment category,
but again, overall thedisputes are very low.
- And what are the ways
that disputes are ultimately resolved?
- Sure, so there are two ways
in which disputes can be resolved,
(38:21):
which is resolved orresolved with no change.
They're the two disputestatuses that you can see
in the system.
Resolved status indicate
that the reporting entity andthe covered recipient reached
a resolution,
and that resolution resultedin an update to the record.
(38:44):
Resolved with no change status means
that the resolution was reached,
but there was no change tothe record made as a result.
So this is often the case
when the covered recipient, for example,
didn't remember receiving
the payment or transfer value
(39:05):
or didn't quite understandwhat it was for,
but the reporting entitywas able to explain
to the covered recipient and confirm
that the transfer of value did occur
and that it was reported correctly.
So in this situation,
the reporting entity can mark
(39:25):
the dispute as resolved
without making any change tothe information on record.
And of course, there isalso the option to withdraw
dispute by the covered recipient.
So occasionally, that happensin a similar situation
when the recipient didn't quite understand
what the payment was for,
but they were able toreach out to the company
(39:48):
outside of the Open Paymentssystem and get the explanation,
and they decided to no longer dispute
that record and withdraw the dispute.
- Could you provide us with an example
so that we can pull all ofthis information together?
- Absolutely, it is a lot of information.
(40:09):
So, I know examples are very helpful.
I'll preface this by saying
that all the names and scenarios
in this sample case study
that we're gonna shareare completely fictional,
so any likeness to individualsis completely coincidental.
So with that being said,
let's talk about a nurse practitioner
(40:29):
who just learned about Open Payments,
and we'll call her Lauren.
So Lauren is reallyfamiliar with interacting
with drug and medicaldevice representatives
in her weekly activities.
Let's say that often a drugrep from Company X brings
her lunch and educates her on medicine
that she could beprescribing to her patients.
(40:49):
In addition to these lunches,
she also accepted an invitation to speak
at Company X's conference
where the company paid
for all of her travel and compensated her
for the presentation that she delivered
at the conference as well.
Well, now that Laurenknows about Open Payments,
she wants to make sure that everything was
(41:09):
recorded accurately
and that there is no incorrect information
on her Open Payments profile.
So Lauren registers inthe Open Payments system
as a non-physician practitioner,
and on April 1st she logs in to review
the data that was submitted about her.
She sees a total of 10food and beverage records
(41:30):
that come to a total of $205,
a travel and lodging record for $1,000,
and a speaking engagement record for $100.
All of this accounts fora total of 12 records
that come to $1,305.
(41:50):
Of those records,
of the 10 food and beverage payments,
Lauren recognizes eight payments,
but knows that one of thefood and beverage records does
not belong to her
because she was actually on vacation
on the date of the payment
and another food andbeverage record for $25
doesn't look correct.
So she initiates a disputeon these two records.
(42:12):
Company X then acknowledges the dispute
and reaches out to Lauren
to come to a resolution.
For the first disputed record,
it's determined that Lauren is correct
and she's not the provider
this payment should be attributed to.
So Company X resolves the dispute
by updating the coveredrecipient information
so it is not associatedwith Lauren anymore.
(42:36):
When Lauren logs into theOpen Payments system again,
she doesn't see the disputedpayment record at all
because it has beenremoved from her profile
and is associated withthe correct provider.
The other disputed record is
determined to, in fact, belong to Lauren,
but Company X sees thatthe total should have been
for $20 and not 25.
(42:57):
So they resolve the dispute
by correcting the total to $20.
Lauren will now see that dispute
as resolved with change
when she logs back in.
She reviews the updated record
and then affirms that it's correct
because the change was made correctly.
- That's a great example, Amy,
but what happens if aclinician doesn't review
(43:19):
the data during the pre-publication review
and dispute period?
For example, the 2024data was just published.
So what if a covered recipient
didn't know to review the data
during the prior periodand wants to do it now?
- Yeah, so this is actuallya pretty common scenario
as people learn about the program.
So we do put a lot of emphasis
(43:40):
on the pre-publicationreview and dispute period
because of it giving ample opportunity
for review of the databefore it's published.
But if someone missedthis review timeline,
they shouldn't worry becausethey can still review
their data.
So the Open Payments datais available for review
within the Open Payments system
through the end of the calendar year.
(44:00):
So, covered recipients have
until the end of each calendaryear to review, affirm
or if needed initiate disputes on data
in the Open Payments systemas we previously discussed.
So the Open Payments team refreshes
the published data in January every year,
which means that any dispute activities,
(44:21):
including data corrections that are made
between now and the end of the year
will be reflected in the data refresh.
So it's important to note
that after December 31st,
the Open Payments systemwill not display records
that were published this year for review.
So nurse practitionerswould be able to see them
on the public-facing site,
but records are only availablein the Open Payments systems
(44:44):
throughout the calendar year
in which they were first published.
So if you missed thereview and dispute deadline
and you wanna review this year's data
within the system sothat you can affirm it
or if needed dispute it,
you'll wanna keep the December31st deadline in mind.
- Yes, Amy and I just wanted to add
(45:06):
that we understand
that the program can seem complex,
and it's a lot of numbers and timelines
and terminology that we just shared,
but we really want the providers to know
that it's actually prettyeasy to review the data.
And while there are many scenarios
(45:28):
that we could discuss
about the timing of whensomeone reviews the data,
the bottom line, it'simportant to review it
even if just for your own sake
of knowing if anythingis reported about you.
So if you missed the reviewand dispute deadline this year,
(45:50):
no worries.
You still have time
and should take the time
to log in to the Open Payments system
and see if there are any recordsthat are attributed to you,
which can also include
those delayed research recordswe talked earlier about,
something that you wouldn't see
necessarily in the public data yet,
(46:12):
but that can still be
non-public in the Open Payments system.
Lastly, I wanted to note
that if you see older data
published on the website
that isn't correct
or that you think is misleading
and should be better contextualized,
(46:33):
but the data isn't available for action
and in the Open Payments system anymore
because it's passed theend of the calendar year
when it was first published,
you can still reach out directly
to the reporting entity
and work with them to get it corrected.
(46:53):
Reporting entities do have
the ability to resubmit the data,
even if it's from a prior calendar year.
So it is still possible
that older data can be corrected too,
but you may need to reach out
to the reporting entity who submitted it
outside of the Open Payments system.
(47:16):
- Thank you both for weighing in on that.
And other than registering
for Open Payments and participating
in the review and dispute process,
which we really encouragenurse practitioners to do,
what other proactive steps are there
that NPs should take in regards
to the Open Payments program?
- Thanks, Frank.
It's really importantfor nurse practitioners
(47:37):
to just have a generalawareness about the program,
including knowing what can be reported
and be prepared in case patients inquire
about the Open Payments data.
I'll just put another plug in
for those annual thresholds
since those do change annually,
that's a good thing.
Once people are aware of the program
and know that things couldbe reported about them,
(47:58):
to keep in mind those dollarthresholds that are reportable.
And of course, reviewingdata every year is crucial.
That way, nurse practitioners know
what data has been attributed to them
and that the data is accurate.
This also helps them know
what's going to be publicly available
so there aren't any surprises.
(48:20):
If you have or expect to havesome data reported about you,
it's important to think aboutwhat questions patients might
ask if they see it
and think through some talking points
that you could respond with.
- Yeah, and I would also add
consider proactivelysharing about Open Payments
and again, using it as opportunity
(48:41):
to build trust with your patients.
For example, in California,
it has now been a state law
for physicians to discloseOpen Payments to patients.
Providers in other states may choose to do
the same on a voluntary basis.
As discussed earlier,
being open about Open Payments is
(49:02):
a good faith gesture that can help enhance
relationship with a patient.
So, do consider sharingwith your patients about it,
maybe via a handout or somekind of notice in the office
to create an open door policy to have
the dialogue about anythingyour patients may have seen.
(49:27):
- This is great, great information
that both of you have provided today.
So how can NPs stay informed
about the Open Payments program
and where can they find all the resources
that you've mentioned?
- We'd love for everyone to stay informed
about the program and use our resources.
We're very happy witheverything that we provide.
And I'll also say thank you here
(49:49):
to the American Associationof Nurse Practitioners
because I know, Frank, thatyou guys help us so much
with sharing our information
and reminding everybodyabout the review and dispute
every year and all of those key deadlines.
But a couple of things to note,
we do have a listserv thatpeople can subscribe to.
So if you visit ourcms.gov/openpayments page,
(50:13):
if you click Contact Us,
there's a box that you can sign up.
Our listserv is our number one way
to get information out about the program.
So that's really thebest way to stay in touch
with the program, hear the announcements.
Of course, we always announcewhen the data's published.
We send reminders of thereview and dispute period
(50:34):
and anything else that'sgoing on throughout the year.
So that is a really keyresource, is the listserv.
A few other things to note is
the Open Payments database.
So if you wanna see wherethe data is published
and the live searchable data,
that's available atopenpaymentsdata.cms.gov.
(50:55):
And as previously mentioned,
we have our general website,
which is cms.gov/openpayments.
This is the main website
for covered recipient resources,
which includes an Open Payments user guide
and other downloadable content.
It also has links to our videos
and that registration quick start guide
(51:17):
that I mentioned earlier,that's on this webpage.
So jot that down and bookmark it
because it will be your bestfriend for program resources.
And then we do have avariety of video tutorials,
including the registration video tutorial,
and a video tutorialthat walks you through
the review and dispute process.
(51:38):
So like Veronika said earlier,
we know there's a lot ofdetails to the program,
but we try to simplify it
and make it very easy
because it is easy and straightforward.
- Well, Veronika and Amy,
we really appreciate all of the work
that you and your teams doin creating those resources.
And thank you again for joining
the "NP Pulse" podcast to inform
(52:00):
nurse practitioners aboutthe Open Payments program.
Your team have been great partners
in providing education on the program,
and we encourage nursepractitioners to enroll
in the program to be able to review
and dispute your data
and go to the OpenPayments website to review
all of those resourcesthat Amy just mentioned.
AANP is also passing along these resources
and other important updates to members
(52:21):
in our weekly government affairs update.
So please make sure to check that out
when we send it out every Monday.
And Veronika and Amy,
I will turn it over to you
for any last items you'd like to mention.
- Thank you so much, Frank,and AANP team for having us.
It has been great to be here with you
and have this opportunityto share about the program.
(52:43):
One closing thought I want to share,
something we didn't talk much about
but a question that often comes up,
something that the patientsmay definitely ask about,
well, how accurate is the data?
Can we trust the data in the database?
So I just wanted to note
that we do put great care into ensuring
(53:05):
the accuracy of data,
both on entry and in compliance review
and through follow-upwith reporting entities.
So since that didn't come up
much in our conversation earlier,
that's one closing point Idefinitely wanted to make,
that we do believe
the data to be pretty accurate
(53:26):
and we take great careto ensure that it is.
- Yeah, and I'll just say thank you again.
This has been an awesome opportunity.
We really appreciate the partnership
and the opportunity to share
the information about the program,
so thank you so much for having us.
- Well, it's been ourpleasure, Veronika and Amy.
(53:46):
So thank you again for joining us,
and we'll make sure to be on the lookout
for all those greatOpen Payments resources
so that we can send themover to nurse practitioners
so that they can stayinformed about the program.
Have a wonderful day.
- Thank you so much.- Thank you.
(upbeat music)
- Well, thank you so much,Amy, Veronika and Frank.
(54:07):
It's been an absolute pleasure
listening to you and gainingyour perspective and insights
on this extremely important topic.
To our listeners, I hope youfound this episode educational
and can apply some of what wasdiscussed to your practice.
Join your NationalProfessional Association
and add your voice to over 120,000
of your NP colleagues nationwide.
(54:29):
I urge you to become an AANP member today.
Membership gives youaccess to so many benefits,
including tools andresources for your practice
and the AANP CE Center,
which offers a comprehensivelibrary of CE activities
for NPs of all specialtiesand experience levels.
Exclusive discounts and manyfree activities are yours
(54:51):
as an AANP member to help you complete
state licensure requirements
and earn the creditsneeded for recertification.
Remember, you may claimCE credit for this program
through August, 2026
by logging in to the CE center
at aanp.org/cecenter.
Register for this program.
(55:13):
Enter the participation code OP2526.
Again, that's OP2526,
and then complete thepost-test and evaluation.
Be sure to subscribe to this podcast,
share with your colleagues
and check back often for new episodes.
Thank you for listening.
(55:33):
(upbeat music)
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