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Yale New Haven Health System

CMS Open Payments reminder for calendar year 2024

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The Centers for Medicare and Medicaid (CMS) Open Payments is a federally run program that provides transparency and increases public awareness of financial relationships between the healthcare industry and certain healthcare providers and teaching hospitals.

The program collects and makes public payments or transfers of value from drug and device manufacturers to certain healthcare providers or teaching hospitals, including:

  • MDs/DOs
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists and anesthesiologist assistants
  • Certified nurse-midwives

Per Open Payments, all transfers of value from an industry representative to certain healthcare providers or teaching hospitals valued at or above $10 or aggregate of $100 per year are reported. Transfers of value may include food and beverage, entertainment, charitable contributions, speaking fees, royalties or licenses, grants, consulting fees, honoraria, travel and lodging, education, research and more. The nature and purpose of the amount must also be recorded and disclosed.

On April 1, CMS began the 45-day dispute period in which healthcare providers can review their 2024 data posted by drug and device manufacturers. This review and dispute period allows physicians and other covered recipients to dispute any inaccurate or incomplete data before it is published to the public on June 30.

Yale New Haven Health providers are accountable for reviewing their 2024 data and disputing any inaccurate information during the review and dispute period, April 1- May 15, 2025.

To review the data, resolve disputes and make corrections, register on the CMS Enterprise Portal and the Open Payments System: https://openpayments.system.cms.gov/.

YNHHS’ Office of Privacy and Corporate Compliance (OPCC) will review CMS Open Payments data once it’s released June 30 and may contact providers about their data if it is not aligned with their most recent Conflict of Interest disclosure survey responses.

Providers should ensure all interactions with drug and device manufacturers comply with the Interactions with Vendors policy: https://ynhh.ellucid.com/documents/view/33702.

For more information, visit the OPCC SharePoint site: http://dept.ynhh.org/OPCC and the Medical Staff Portal: http://www.ynhhconnect.org. Questions or concerns? Contact the OPCC, at 203- 688-8416 or conflictofinterest@ynhh.org.