Payment Transparency NPs PAs Dermatology
The Open Payment program by the Centers for Medicare and Medicaid Services’ (CMS) will be updated in 2021 to include five new provider types: Physician assistants, Nurse practitioners, Clinical nurse specialists, Certified registered nurse anesthetists, Anesthesiologist assistants, and
Certified nurse-midwives. This national disclosure database provides the public with information about the financial relationships between pharmaceutical industries, medical-device manufacturers, and group purchasing organizations (GPOs) and healthcare providers and/or teaching hospitals. Physicians have been part of this reporting program since 2015. The 2021 calendar year will be an information collection period for all new provider types; and beginning midsummer of 2022, CMS will display all 2021 financial relationship data.
According to the American Academy of Physician Assistants (AAPA) website, legitimate transfers of value (or payments) to healthcare professionals may include¹:
- Serving as faculty or as a speaker for an accredited or certified continuing education program, such as speaking at a medical conference;
- Serving as faculty or as a speaker at an event other than a continuing education program, such as giving a medical talk to other health professionals at a local restaurant;
- Providing consulting services, advice or expertise to a pharmaceutical or medical device company regarding the use of a particular drug, product or treatment regimen;
- Engaging in research activities including coordination a study or enrolling patients into studies;
- Having an ownership or investment interests in an applicable manufacturer or applicable group purchasing organization; or,
- Appropriate transfer of value including receiving gifts, promotional products, entertainment, food and beverage, or lodging and travel.
The Open Payments program does not require NP/PAs to register or enroll, but rather, pharmaceutical and medical device companies are obligated to report names and NPI numbers to the CMS when a reportable financial transaction takes place. Yet, if a provider wants access to reported information on the CMS data bank, they must first register via the CMS.gov Enterprise Portal and then request access to the Open Payments system. Financial transaction information can be disputed by a healthcare professional prior to public-access posting. In short, the CMS can levy penalties against pharmaceutical/device companies that do not report complete financial information to the Open Payment Program, but it is the responsibility of an individual professional to ensure the veracity of data being collected and displayed to the public.
For more information:
List of applicable financial relationships
References:
1. CMS Mandatory Reporting Program to Include PAs. For the First Time, PAs and APRNs to be Displayed on Open Payments Website. Accessed December 20, 2020. https://www.aapa.org/news-central/2020/11/cms-mandatory-reporting-program-to-include-pas/
Douglas DiRuggiero, DMSc. PA-C, and his wife live in the foothills of Northwest Georgia where he has practiced dermatology for the past 21 years. His three college-aged kids have diverse pursuits which include elementary education, military special forces, and healthcare. They all enjoy traveling, getting outdoors, helping those in need, quoting phrases from "The Office," and putting together complex jigsaw puzzles.