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The Top 6 Pitfalls in CMS Open Payments Reporting & How to Navigate Them Successfully

Did you know? Failure to report complete and accurate CMS data on time can result in Penalties and Fines of up to $1,150,000. 

  1. For compliance officers and life sciences companies, staying ahead of the curve means a keen understanding of the changes and updates in reporting requirements and the agility to navigate unexpected twists and turns.

To better address some of the challenges in CMS Open Payments reporting, you should also check out frequently asked questions (FAQs) for compliance Officers.

Top 6 Challenges in CMS Open Payments Reporting

1. Keep Up With Updates In Reporting Requirements

Compliance officers are responsible for ensuring that companies follow the rules set by CMS (Centers for Medicare & Medicaid Services). They’re like guides in a constantly changing terrain of regulations. These changes come from all sorts of places, like updates to state or federal laws, CMS guidelines, or industry standards. 

Compliance officers must stay informed about regulatory changes. They must closely monitor updates, accurately interpret their impact, and make necessary adjustments quickly to prevent compliance issues.

2. Data Quality

Life science companies handle a wide range of data from different sources, including financial transactions with healthcare professionals (HCPs) and healthcare organizations (HCOs). Ensuring the accuracy and reliability of this data is one of the most crucial aspect for compliance with transparency reporting requirements. 

Validating data involves verifying the integrity of information such as HCP/O identities, transaction details, and payment amounts. Disputes may arise from inconsistencies, errors, or discrepancies in the data collected from disparate sources. 

Compliance officers must implement robust data validation processes, which may include data cleansing, standardization, and reconciliation, to ensure the quality and integrity of the reported information.

3. Lack of Resources

Managing CMS open payments reporting requires significant resources in terms of manpower, expertise, and technology. Many companies may lack the necessary capacity or specialized knowledge to effectively collect, analyze, and prepare their spend data for reporting purposes. Limited resources can hinder the timely and accurate completion of reporting tasks, leading to compliance risks. 

4. Data Silos

Data fragmentation across different departments or functional areas within a company can impede the seamless aggregation and analysis of spend data for open payments reporting. Information related to payments made to HCPs/HCOs may reside in disparate systems or databases, leading to data silos. The existence of these silos prevents obtaining a comprehensive and accurate view of the company’s spending activities. Centralizing and consolidating data sources can help life sciences companies overcome this challenge and achieve greater transparency and accuracy in their reporting.

5. Lack of Early Data Visibility

A common pitfall in open payments reporting is the limited visibility into final reportable data until very close to the reporting deadline. This lack of early visibility leaves little time for compliance officers to conduct thorough quality checks and address any discrepancies or errors before submission. The compressed timeline increases the risk of inaccuracies slipping through unnoticed, potentially leading to compliance violations or regulatory penalties. 

6. Manual Data Remediation

Correcting inaccuracies or anomalies in open payments data often requires manual intervention and remediation efforts, which can be time-consuming and resource-intensive. Compliance officers may encounter challenges such as identifying outliers, resolving duplicate transactions, reconciling discrepancies, and addressing other data anomalies. Manual remediation processes are prone to human errors and may not be scalable or efficient, especially when dealing with large volumes of data. 

How To Navigate These Pitfalls Successfully?  

Proactive Compliance Monitoring and Training

Implement a proactive approach to compliance by establishing regular monitoring of regulatory updates and changes. This can involve subscribing to regulatory alerts, participating in industry forums, and engaging with regulatory agencies to stay informed about evolving reporting requirements. Additionally, invest in ongoing training programs to ensure compliance officers and relevant staff members are well-versed in the latest regulations and best practices.

Data Governance and Quality Assurance Processes

Develop robust data governance frameworks and quality assurance processes to ensure the accuracy and reliability of spend data. This includes implementing data validation checks, conducting regular audits, and establishing clear protocols for data collection, normalization, and reconciliation. By maintaining high standards of data integrity, companies can minimize the risk of reporting errors and compliance violations.

Resource Allocation and Capacity Building

Allocate adequate resources and invest in capacity-building initiatives to support open payments reporting efforts. This may involve hiring skilled personnel, investing in technology infrastructure, and outsourcing specialized tasks to external experts. By dedicating sufficient resources to compliance activities, companies can enhance their ability to collect, analyze, and report spend data accurately and efficiently.

Integration and Collaboration Across Departments

Break down data silos and promote integration and collaboration across departments and functional areas within the organization. Implement integrated data management systems and standardized reporting processes to facilitate seamless aggregation and analysis of spend data. By fostering a culture of collaboration and communication, companies can improve the accuracy and completeness of their reporting while minimizing the risk of data discrepancies.

Early Data Visibility and Real-Time Monitoring

Invest in technology solutions that provide early visibility into spend data and enable real-time monitoring of compliance metrics. By leveraging data analytics and visualization tools, compliance officers can identify potential issues and anomalies early in the reporting cycle, allowing sufficient time for remediation before the reporting deadline. This proactive approach helps minimize the risk of last-minute compliance challenges and ensures the timely and accurate submission of reports.

Automation and Advanced Analytics

Implement automation tools and advanced analytics capabilities to streamline data remediation processes and enhance the efficiency of compliance activities. This includes deploying machine learning algorithms to identify and resolve data discrepancies, automate repetitive tasks, and improve the accuracy of reporting. By leveraging technology solutions, companies can reduce reliance on manual processes, increase productivity, and achieve greater compliance with open payments reporting requirements.

What Do We Recommend To Achieve Compliance Excellence? 

If you want to increase the effectiveness of your CMS open payments reporting program, get in touch with a team of experts with years of experience in the compliance industry. 

One of your top choices should be getting on a strategy call with qordata, known for helping life sciences companies overcome increasing regulatory and board scrutiny. Their  CMS open payments reporting solution brings visibility to your data at all times to ensure accurate, complete, and timely CMS open payments reporting. 

You can also leverage their freemium version of qorAI (CMS chatbot), enabling you to drill down into specific data points from previous years’ published CMS data for detailed analysis and actionable insights into spending patterns, payment trends, specialties, and more. 

Wrap Up 

In conclusion, navigating the complexities of CMS Open Payments reporting requires diligence, attention to detail, and a commitment to compliance. By addressing the top six pitfalls outlined above and implementing best practices in data collection, reporting processes, and internal controls, life sciences companies can successfully navigate the challenges of CMS Open Payments reporting and uphold transparency and accountability. 

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