CIS Offers Initial Observations and a Webinar to Help Address Operational Challenges Related to CMS' Teaching Hospitals List

Top Quote Compliance Implementation Services (CIS), a leading life sciences consulting firm, announced that on Friday, May 3, CMS published its list of Teaching Hospitals in conjunction with OPEN PAYMENTS, the CMS program under which applicable manufacturers and group purchasing organizations (GPOs) will begin tracking and reporting payments and other transfers of value to physicians and teaching hospitals. End Quote
  • Philadelphia, PA-NJ (1888PressRelease) May 08, 2013 - In the final rule, CMS committed to publishing a list of Teaching Hospitals annually and at a minimum of ninety (90) days prior to data collection each year. Under OPEN PAYMENTS, "teaching hospitals" are hospitals that received payment for Medicare direct graduate medical education (GME), inpatient prospective payment system (IPPS), indirect medical education (IME), or psychiatric hospital IME programs during the last calendar year that the information is available.

    The list is the only real resource for applicable manufacturers to determine if a transfer of value made to a hospital is reportable. The list is available in three formats: CSV, Microsoft Excel and Adobe PDF and includes the hospital's legal business name, Tax identification number (TIN), street address, city, state and zip code. The list will be valid for the entire 2013 reporting cycle. More details about the list and CMS' recommendations are available in today's blog article.

    "The integrity of the data capture process and strategies for ensuring a high level of confidence in the accuracy and completeness of the data can be challenging with just a first glance at the CMS list," said Judy Fox, Director, Transparency Compliance at CIS. "When we thought we had all we could handle, assessing readiness for reporting OPEN PAYMENTS just jumped up another level."

    To help manufacturers address these challenges, CIS will hold a complimentary CIS Insights webinar, "Sunshine Readiness Assessments: Assessing Beyond the Basics," that will provide a step-by-step "readiness assessment" plan to help identify gaps and remediate concerns in preparation for federal transparency and disclosure reporting. CIS' subject matter experts will help ensure that companies' implementation plan are aligned with interpretations of the regulations, impacted business activities, data being collected and any systems used for data capture.

    Fox adds, "Scrutinizing the list and testing data capture, master data management and recipient data master lists, and how it will all map for reporting needs to be tested now to ensure any payments made after August 1, 2013 will not only be reported, but supported with appropriate documentation and details."

    About Compliance Implementation Services (CIS)
    Compliance Implementation Services (CIS) is a consulting firm focused on helping life sciences clients proactively manage complex compliance requirements. We offer a broad portfolio of services and solutions that expand deep into the clinical, manufacturing and commercial disciplines and that align with our clients' strategic priorities and business operations. CIS continually provides leadership, global regulatory knowledge, industry experience and a problem-solving culture that responds to today's compliance and commercial challenges. For more information, visit

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