The Academy responded to a request from the Centers for Medicare & Medicaid Services (CMS) for comments related to Revisions to the Payment Policies under the Physician Fee Schedule. The questions focused on the Open Payment Final Rule (section 1128G of the Act) that was added by section 6002 (Sunshine Act) of the Affordable Care Act. Comments were submitted by the Academy on September 6, 2016 as required by CMS.
The Academy’s comments to CMS centered on the reporting of gifts, data collection and reporting, categories of payments, and definitions of what constitute a “teaching hospital.” The Open Payment Final Rule has had some unintended consequences that have caused over-burdensome reporting and record keeping requirements for academic researchers. You can read the Academy’s full response letter here.