Hogan Lovells Publications | Health Alert | 16 August 2019

A bit more Sunshine: CMS proposes collecting additional information on manufacturer payments under the Open Payments program

Device and drug manufacturers got a small surprise in the annual Physician Fee Schedule proposed rule (at 40,713-16) issued late in July by the Centers for Medicare & Medicaid Services (CMS) – among many other things, the proposed rule would make a few changes to manufacturer reporting requirements under the Open Payments program.

Although the proposed changes would require manufacturers to capture new covered recipients and (for device manufacturers) report an additional device identifier, many companies should be able to leverage existing systems to respond to the new requirements. Manufacturers may want to build the new device identifier and nature of payment categories into their systems for calendar year (CY) 2020, and consider using CY 2020 as a practice year for tracking payments to new covered recipients before those requirements take effect in CY 2021.

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