sunshine act overview
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Open Payments Phase 1 Step-by-Step CMS Enterprise Portal Registration for
Physicians and Teaching Hospitals
Ju ne 2014
CMS Disclaimer: This information is a summary of the final rule implementing Open Payments (Medicare, Medicaid, Children's HealthInsurance Programs; Transp arency Reports and Reporting of Physic ian Ownership or Inv estment Interests [ CMS-5060-F], codif ied at 42 CFRParts 402 and 403) The summary is not intended to take the place of the final rule which is the official source for information on the program.
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Open Payments (the Sunshine Act)Review
Payments or other transfers of value made
to physicians and teaching hospitals. Certain ownership or investment interestsheld by physician owners or investors ortheir immediate family members.
Applicable manufacturers ofcovered products AND entities
under common ownershipwith applicable manufacturers
who also provide assistanceand support are required to
annually report to CMS:
Payments or other transfers of value madeto physicians.
Certain ownership or investment interestsheld by physician owners or investors andtheir immediate family members.
Applicable group purchasingorganizations (GPOs) are
required to annually report toCMS:
Who is responsible for reporting?
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Registration Overview
Registration is required for physicians and teachinghospitals to review or dispute the followinginformation reported about them by applicable
manufacturers and GPOs: Payments made to physicians and teaching hospitals, Other transfers of value made to physicians and teaching
hospitals, or Ownership or investment interests held by physicians or
their immediate family members Registration will be conducted in two phases this first
reporting year.
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Phase 2 Registration for Physicians andTeaching Hospitals: Open Payments System
Begins July 2014
Physicians and teaching hospitals useEIDM registration credentials to register in
the Open Payments system Once physicians and teaching hospitals are
registered in the Open Payments system,they are able to participate in the review,and dispute process
July2014
*Guidance on how to use EIDM registration credentials to register in the OpenPayments system, and how to review and dispute submitted data is forthcoming
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Phase 1 Registration in EIDM:Identity Verification Process
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EIDM Identity Verification Overview
CMS Enterprise Identity Management system(EIDM) is how CMS verifies user identities
Identity verification is the process of providinginformation (e.g., identity history, credentials, ordocuments) for the purpose of proving that aperson is the same person he or she claims to be
Individuals requesting electronic access to CMSprotected information or systems must first havetheir identities verified
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EIDM Identity Verification (cont.)
All users who register for EIDM have their identities verified EIDM matches information entered by users to information provided
by Experian Out of Wallet (OOW) questions are also used to verify identity OOW questions ask for private data and contain information pulled
from your credit report such as: Mortgage lender name
Previous employer name Auto lender name
OOW questions and answers are shared only between the EIDMregistrant and the verification service provider, Experian; the
information will not be stored in EIDM
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EIDM Identity Verification (cont.)
A soft credit inquiry will be made during EIDMregistration
Soft credit inquiries are visible only to the EIDM
registrant and only appear on credit reportsproduced by Experian (shown as an inquiry made byCMS)
Identity proofing does not affect credit score Contact Experian Proofing Support Services for
assistance with failed identity proofing:1-866-578-5409
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Phase 1 Registration:EIDM New User Registration
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EIDM Registration Overview
EIDM registration is required for accessto the Open Payments system
EIDM registration process is the same forall users You may already have an EIDM account if
you use the Health Insurance OversightSystem (HIOS), the Medicaid and CHIPProgram System (MACPro), or other CMSsystems
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Step 1: Go to CMS Enterprise Portaland Select New User Registration
https://portal.cms.gov
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Step 2: Accept Terms & Conditions
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Step 2: Accept Terms & Conditions(cont.)
Two sections are particularly important to read:
1. Consent to monitoring
2. Collection of Personal Identifiable Information or PII
Consent to monitoring means that you agree to allow CMS to monitor you whileyou are on systems accessed through EIDM
PII is information that can be used to uniquely identify, contact, or locate a singleperson or can be used with other sources to uniquely identify a single individual;PII is collected to aid in the identity verification process
Identity verification is required for all users requesting access to any CMSapplication
Personal information collected will be used for the purposes of verifying youridentity only
Once you have read the terms and conditions, check the box labeled I agree tothe terms and conditions before selecting Next to continue
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Step 4: Select User ID, Password, andChallenge Questions
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User ID and Password Criteria User ID
Must be a minimum of 6 and a maximum of 74 characters Special characters permitted: dashes (-), underscores (_), apostrophes
('), periods (.), and at signs (@) Password
Must be a minimum of 8 and a maximum of 20 characters Must contain at least 1 number, 1 uppercase letter, and 1 lowercase
letter
Cannot contain your user ID and must differ from your previous 6passwords
Must be changed every 60 days EIDM will prompt for password change when the 60 day deadline
approaches
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Step 5: Registration Complete
Click on OK to exit and return to the CMS Enterprise Portal home page.
After clicking on OK, you will receive a confirmation email message that containsyour user ID and a link to the CMS Enterprise Portal.
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Confirmation Email
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Unsuccessful EIDM Registration
Individuals with addresses outside of theUnited States may not register successfully in
EIDM They should contact the Open Payments Help
Desk for assistance with EIDM registration Any additional EIDM issues should be directed
to the Open Payments Help Desk [email protected]
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Using EIDM Registration Credentials to
Request Access to theOpen Payments System
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Requesting Access to the OpenPayments System
In Phase 2 registration, this request inEIDM will allow the individual access to
the Open Payments system Request for this access can occur only
after EIDM registration is successful Request for this access is made through
the CMS Enterprise Portal
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Step 1: On CMS Enterprise Portal,select Login to CMS Secure Portal
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Step 2: Accept Terms & Conditions
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Step 3: Enter EIDM User ID andPassword
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Step 4: Select Request Access Nowunder Request Application Access
After a successful CMS Enterprise Portal login, you will be taken to the CMS Portalhome page (shown below).
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Step 5: Select Request NewApplication Access
If you have access to other CMS applications, you will see thoseapplications listed in the View and Manage My Access table.
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S i d i ifi i
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Step 7: Review Identity VerificationInformation
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Step 8: Accept Terms & Conditions
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Step 9: Confirm Your Information
Some fields willbe pre-populatedwith information
from your EIDMprofile.
Confirm its
accuracy; editfields to correcterrors.
S 9 C fi Y I f i
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Step 9: Confirm Your Information(cont.)
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Step 10: Verify Identity
As previouslyexplained, identityproofing questionsare pulled from the
soft-credit inquirydone during EIDMregistration.
Out-of-Wallet(OOW) questions arebased uponinformation in yourcredit report.
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Step 11: Verifying Identity Successful
St 12 R ti A li ti
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Step 12: Requesting ApplicationAccess Successful
Access may take a few minutes to process Log out of EIDM and log back in to view if it was successful
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Open Payments Access Successful
Log back into theCMS EnterprisePortal to see theOpen Payments tabin the menu bar atthe top of thescreen.
It may take a fewminutes for theOpen Payments tabto appear.
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Next Steps
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What You Can Do Now
Complete Phase 1 by: Registering for your EIDM user ID and password Requesting access to the Open Payments system via
EIDM Review resources on the CMS Open Payments website:
http://go.cms.gov/openpayments
Register on CMS listserv to receive e-mail updates aboutthe Open Payments program go tohttp://go.cms.gov/openpayments and enter emailaddress on the main page, in the "Email Updates" box
http://go.cms.gov/openpaymentshttp://go.cms.gov/openpaymentshttp://go.cms.gov/openpaymentshttp://go.cms.gov/openpayments -
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2014 Open Payments Timeline
Feb March April May June July Aug SeptPhase 1 Registration and
Submission
Applicablemanufacturers andapplicable GPOs
Submission ofcorporate profile andaggregate data
Phase 2 Registration andSubmission For Industry
Applicable manufacturers andapplicable GPOs
Step 1 June 1 June 30
Step 2 June 9 June 30
Detaileddatapublishedon public-facing CMSwebsite
Phase 1 Registration for Physiciansand Teaching Hospitals
CMS Enterprise Portal (EIDM)
Phase 2 Registration forPhysicians and Teaching
Hospitals
Open Payments system
Review, Dispute, and
Corrections
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Resources Available
CMS Open Payments website:http://go.cms.gov/openpayments Physician and Teaching Hospital pages of the website
Events page: Open Payments technology-focusedwebinar recordings and materials, plus a schedule ofupcoming webinars
Program Registration page: Supplemental materials,
instruction documents, FAQs & other resources Open Payments Help Desk:
[email protected] or 855-326-8366
http://go.cms.gov/openpaymentsmailto:[email protected]:[email protected]://go.cms.gov/openpayments