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Why Open Payments Matters for Life Sciences Companies

The Open Payments program is a transparency program that provides clarity between Pharmaceutical Manufacturers and the payments they make to healthcare providers and teaching hospitals.

As  Pharmaceutical Manufacturers, Open Payments require you to report all direct and indirect payments or transfers of values made to physicians, teaching hospitals, and basically anyone in the healthcare sector classified as “Covered Recipient” under the CMS final rule. With the start of 2021, the CMS has divided recipients into five new categories:

  1. Physician Assistants

  2. Nurse Practitioners

  3. Clinical Nurse Specialists

  4. Certified Registered Nurse Anesthetists and Anesthesiologist Assistants

  5. Certified Nurse-Midwives

The report is published every year by the month of June. The CMS has also brought forward severe penalties in cases where the manufacturer fails to report entries of payments.

Let us help you understand why the Open Payment system matters and how it would help you in the long run.

Physician Assistant

Since the start of 2013, the Open Payments program has reported $53.06 billion in payments and $76.25 million in total records. A total of 2,000 reports were filed at the end of the fiscal year. All these payments are reported by 1.08 million physicians and 1300 teaching hospitals.

From 2021, physician assistants are now required to report any payments or transfers made to them by Pharmaceutical Manufacturers or their distributors. All the reported data is filed and released publicly at the end of the fiscal year, in this case, 2022. These transactions can and may include:

  • Consulting and speaking fees

  • Honoraria

  • Gifts and royalties

  • Grants and research charitable contributions

  • Entertainment, travel, lodging, food, beverage

  • Faculty compensation

  • Space rental or facility fees

From April of the year 2022, physician assistants will be eligible to review the payment or transfer information regarding them reported to the CMS before the CMS publishes it in the Open Payments System. Physician assistants can register themselves from the end of January next year so that you can also review your information before it becomes public.

Nurse Practitioners

Nurse practitioners have now been added to the list of Covered Recipients. A nurse practitioner must be a registered nurse. The basic eligibility criteria for this are a Bachelor of Science in Nursing, complete a nurse practitioner-focused graduate master’s or doctoral nursing program, and then successfully pass the national nurse practitioner board certification exam.

Clinical Nurse Specialists

As of 2021, clinical nurse specialists have also been added to the list of Covered Recipients under the Sunshine Act Open Payments. Clinical nurse specialists serve as experts on nursing staff and can might be working in management positions to develop healthcare policies and procedures.

Certified Registered Nurse Anesthetists and Anesthesiologist Assistants

According to the new regulations by CMS,  Certified Registered Nurse Anesthetists and Anesthesiologist Assistants they are also listed under the Covered Recipients list. CRNAs work as advanced nurses who administer anesthesia. Anesthesiologist assistants are those work under the direction of licensed anesthesiologists as part of the anesthesia care team.

Certified Nurse-Midwives

A certified nurse-midwife is a trained professional that also comes under the CMS list of Covered Recipients. They are trained professionals who are trained in a wide array of specialties that cater especially but not limited to, pregnant women and newborn babies.

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