HealthStream offers performance learning management solutions to help develop your healthcare staff into leaders and reduce turnover.
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View All ProductsIn all areas of resuscitation, from neonatal to elderly care, clinical deterioration is a risk that can be avoided with the help of HealthStream's training programs.
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View All ProductsMake sure your clinicians have the support they need to provide competent care with clinical competency training and development from HealthStream.
View All ProductsHealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All ProductsThe suite of healthcare onboarding solutions available from HealthStream aids in nurse retention and improved patient outcomes.
View All ProductsGive your healthcare staff the decision support and skills training they need with the online products available from HealthStream.
View All ProductsHealthStream leverages medical professional development in healthcare by providing staff training programs
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View All ProductsUnlocking the full potential of clinicians goes beyond aspiration – it’s a commitment we embody. Our competency development solutions help personalize learning for every clinician so you can confidently bridge the gap between theory and practice for your nurse residents while meeting the unique development needs of your seasoned clinician.
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View All ProductsMitigate risk and elevate your quality of care. Improving both clinical and business outcomes starts with a smarter, more integrated approach to regulatory training, continuing education and quality management.
Learn MoreAuthor: Rebecca Scott, Product Specialist at HealthStream
Rebecca Scott has more than 23 years of experience in the field of Higher Education Administration, the last 13 of which were spent managing clinical trial billing compliance, clinical research risk, and conflict of interest (COI) management for a large academic medical center. Scott joined HealthStream in 2020 and is a COI thought leader who assists clients with COI best practices, efficient product utilization, and managing COI risk.
Most compliance officers and health systems are familiar with CMS’s Open Payments database. Since its inception in 2010 and its initial publication in 2014 through today, CMS has collected data on financial transfers of value from applicable manufacturers and group purchasing organizations (GPOs) to more than one million providers in the US. That number is about to grow, but what does this mean?
If we look back to the Physician Payment Sunshine Act, which was part of the Affordable Care Act of 2010, we recall that applicable manufacturers and group purchasing organizations, simply stated as drug and device companies, have to collect financial information detailing how much money and gifts they give each year to physicians, surgeons, dentists, certain osteopaths, and teaching hospitals. These payments are collectively known as “transfers of value,” and these providers are called “covered recipients.” These transfers of value are reported separately in the Open Payments database under the categories General Payments, Research Payments, Associated Research Funding, as well as Ownership and Investment Interest. Some of these categories encompass sub-categories. The burden of data accuracy and reporting rests on the drug and device manufacturers and GPOs.
The reporting cycle on which these transfers of value are tracked has changed very little from the first full year of financial data reporting and are not likely to change in the future. Applicable manufacturers begin tracking transfers of value in January every year through the end of December. The following year they report these transfers of value to CMS, which then makes the data privately available to providers and teaching hospitals during the Review and Dispute phase. CMS allows 45 days for teaching hospitals and providers to file disputes with the applicable manufactures and GPOs if they determine the data is not accurate. These conversations are between the covered recipients and the drug and device companies and GPOs, not CMS. After the Review and Dispute period closes, CMS makes the data publicly available on the Open Payments website on or before June 30 each year. The financial data, therefore, is always a retroactive look at the previous calendar year.
A thorough understanding of the Open Payments reporting cycle is critical in the context of the SUPPORT Act of 2018. The SUPPORT Act is a large collection of Acts that are all intended to fight the Opioid Crisis in America. Section 6111 of the SUPPORT Act, Fighting the Opioid Epidemic with Sunshine (FOES), statutorily caused the types of covered recipients to expand beyond physicians, surgeons, dentists, and osteopaths. In response to the SUPPORT Act, CMS issued a Final Rule on November 1, 2019 to expand the definition of covered recipients to include physician assistants, nurse practitioners, clinical nurse specialist, certified nurse midwives, and registered nurse anesthetists. The Final Rule also updated the General Payments category to add debt forgiveness, long term medical supply or device loan, and acquisitions as sub-categories. Furthermore, the Final Rule combined the two payment sub-categories for continuing education teaching and non-continuing education teaching into one single category and added reporting requirements for manufacturers and GPOs to include device identification numbers for devices and medical supplies in the Open Payments dataset.
Beginning January 1, 2021, applicable manufacturers and GPOs will begin collecting financial transfer of value information for both the original provider categories and the new. They will collect that information and send it to CMS in the spring of 2022. CMS will publicly publish the expanded data, including the new transfer of value sub-categories, no later than June 30, 2022.
Health systems, teaching hospitals, and all provider types should be ready for this transition. Physicians assistants and nursing staff should receive Conflict of Interest training along with other providers. Institutions should review internal policies and communicate any updates to providers as soon as possible. Continuing Medical Education providers should ensure their speakers are aware of the change in CE-related sub-categories and voice internal expectations to their speakers. Compliance Offices should review their internal conflict of interest disclosure policies and practices and ask themselves if they’re asking the right questions of the right people across all demographics of their organizations in order to identify, mitigate, and manage financial, legal, and reputational risk.
Learn more at https://www.cms.gov/OpenPayments/About/Law-and-Policy
HealthStream provides online healthcare compliance solutions to help health systems, facilities, and organizations across the care continuum comply with government regulations and accrediting body requirements. COI-SMART™ provides comprehensive tools for tracking and managing Conflicts of Interest (COI) disclosures. Learn more.
HealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All Learning & PerformanceHealthStream offers performance learning management solutions to help develop your healthcare staff into leaders and reduce turnover.
View All ProductsHealthStream works with healthcare organizations to create engaging and high-quality training videos for your staff and management.
View All ProductsImprove care quality and save money by making informed decisions about your healthcare facility and staff with HealthStream's reporting analytics solution.
View All ProductsHealthStream's proven methods for the improvement and overall engagement of your healthcare staff foster a positive workplace and increase retention rates.
View All ProductsWhen you enact HealthStream's quality compliance solutions, you can do so with the confidence your healthcare organization will meet all standards of care.
View All Quality & ComplianceBe confident in your staff’s ability to reduce risk by providing compliance training that changes behavior.
View All ProductsDevelop next-level people for next-level care by prioritizing quality and safety improvements.
View All ProductsStandardize policy and procedure management with an automated, customized, and centralized system.
View All ProductsEstablish a culture of belonging with education supporting DEI, wellness, engagement, and leadership development.
View All ProductsHealthStream offers professional training and education on how to best optimize your reimbursement process within your healthcare organization.
View All ReimbursementStreamline the revenue cycle management process and protect your bottom line with expert-backed education.
View All ProductsLearn about our advanced resuscitation training solutions. Our solutions are designed to help improve patient outcomes.
View All ResuscitationIn all areas of resuscitation, from neonatal to elderly care, clinical deterioration is a risk that can be avoided with the help of HealthStream's training programs.
View All ProductsNurture the skills of your nurses and medical staff to help mold them into effective leaders with development training from HealthStream.
View All ProductsExpand the decision-making skills and effectiveness of your healthcare workforce with HealthStream's clinical development programs and services.
View All Clinical DevelopmentMake sure your clinicians have the support they need to provide competent care with clinical competency training and development from HealthStream.
View All ProductsHealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All ProductsThe suite of healthcare onboarding solutions available from HealthStream aids in nurse retention and improved patient outcomes.
View All ProductsGive your healthcare staff the decision support and skills training they need with the online products available from HealthStream.
View All ProductsHealthStream leverages medical professional development in healthcare by providing staff training programs
View All ProductsMake sure your healthcare staff can schedule out appointments and work schedules with ease using HealthStream's line of software solutions.
View All SchedulingHealthcare workforce management is essential. We provide advanced scheduling solutions for organizations to solve issues such as nurse retention
View All ProductsComprehensive, industry-leading provider onboarding and credentialing software that validate health outcomes and support provider assessment.
View All CredentialingOur affordable CVO credentialing services establish patient safety by enabling primary source verification for your healthcare organization.
View All ProductsIntegrate with Epic to validate and add new providers directly to your provider master file.
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