Re: Open Payments Program: Registration Processes / Review, Dispute and Correction of
Public Data
Dear Administrator Tavenner:
On behalf of the Alliance of Specialty Medicine (the Alliance) and its member organizations, we write
to share concerns with the implementation of the Open Payments program. The Alliance is a coalition
of medical specialty societies representing more than 100,000 physicians and surgeons dedicated to
the development of sound federal healthcare policy that fosters patient access to the highest quality
specialty care. Our members are concerned about difficulties accessing and completing registration for
Open Payments in a timely manner and believe that the program’s structure lacks adequate means to
limit publication of inaccurate information, which harms both patients and providers.
Throughout the Open Payments rulemaking process, our societies have supported the underlying goal
of transparency, while also believing that relationships between physicians and the health care
industry can lead to important advancements in technology and improved patient care. We have also
been receptive to efforts to develop uniform procedures for disclosing relevant information in a way
that minimizes confusion and misrepresentation. However, we ask that the Centers for Medicare and
Medicaid Services (CMS) address the following concerns prior to publication of any financial data.
Difficult Registration Process Needs Sufficient Clarity and Enhanced Guidance
The Alliance appreciates the time constraints and daunting logistical concerns that CMS faced while
implementing Open Payments. In that regard, the specialty medicine community applauds the
ongoing flow of information facilitated by officials at CMS, which continues to be of great value to the
provider community. However, we are concerned that the lack of adequate notice before the
beginning of registration periods has handicapped providers that hope to participate in the program in
a meaningful manner. This concern is magnified by the lengthy registration process and the obstacles
it poses.
Given the importance of sufficient participation levels and the role of physicians in ensuring data
integrity, the Alliance is concerned that the failure to provide sufficient notice could be a detriment to
the program’s performance. Further, members of the provider community have legitimate worries
about the lack of guidance and the complexity of enrollment mechanisms. We respectfully ask that
CMS provide additional provider-specific guidance for the registration process and adopt policies that
allow for flexibility of enrollment requirements so that physicians struggling to enroll remain able to
participate prior to data publication.
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Read full letter here
