The Health and Human Services Office of Inspector General (OIG) recently released a report on its review of the Open Payments program, titled “OPEN PAYMENTS DATA: REVIEW OF  ACCURACY, PRECISION, AND CONSISTENCY IN REPORTING.” The OIG reviewed data from calendar year 2015 available as of June 2016. The OIG’s key takeaway from the review was that “[a]lthough almost all the 2015 data reported in the Open Payments program met requirements, there were several areas where CMS could improve data accuracy, precision, and consistency to better help consumers use the information.” This includes (1) ensuring that records contain all required data; (2) strengthening  validation rules and revise data-element definitions so that actual drug and device names must be reported; (3) revising the definition of the device-name data element so that the information reported is required to be more specific; and (4) ensuring that manufacturers and group purchasing organizations report valid NDCs for drugs.

Of the 11.9 million records associated with $7.5 billion in reported payments and ownership interests,  less than 1% (11,463) of records were missing one or more required data elements, with the most common arising from physician specialty designations. However, the OIG determined other records contained inaccurate, imprecise, or inconsistent information, including information related to product names and NDCs. Additionally, the OIG determined that although the Centers for Medicare & Medicaid Services (CMS), reviewed all 199 reasonable assumptions submitted by applicable manufacturers and group purchasing organizations (GPOs), no followup was conducted by CMS with these entities regarding such assumptions.

The OIG noted that it analyzed only financial relationships published on the Open Payments website, and did not determine whether there were manufacturers and GPOs that failed to submit all required financial relationships for all covered recipients.

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