How a hospital compliance program should monitor Open Payments

Every payment industry makes to your medical staff is published, by name, in a federal database your board, your accreditors, and any journalist can read. Monitoring it is not a product question. It is a program question: who checks the record, on what calendar, and what happens when it is wrong. Here is a workable shape for that program.

The calendar your program inherits

Companies submit their reports to CMS from February 1 to March 31. Physicians and teaching hospitals review and dispute from April 1 to May 15. Companies correct disputed records until May 30, and CMS publishes the program year by June 30. For program year 2025 those dates fell in 2026. Review and dispute activity stays possible inside the Open Payments system through December 31. Then the records close until the next review period opens on April 1. Edits to undisputed records made before mid-November land in the January refresh. Later edits wait for the next June publication. The current dates are always at cms.gov. Four consequences follow. The window where an error can be fixed before it publishes is 45 days. A record a company adds or corrects after review closes on December 31 is first shown to the physician on the next April 1, and the public file carries the old number the whole time. A record submitted after the March deadline is not published until the following June. And a program year is never final: what you verified in July can read differently in February.

What to reconcile, and when

The annual conflict-of-interest attestation and the public record describe the same relationships from two directions, and each is incomplete without the other. The attestation is what the physician remembers. The database is what industry reported. A monitoring program compares them after each June publication and again after the January refresh. The comparison is harder than it sounds because the public file is keyed by company, so one physician's complete picture spans every filer's records, and no single company can see more than the sliver it filed.

Who to sample first

If reviewing everyone is not realistic, sample where the exposure concentrates: principal investigators, whose research funding is attributed to them personally in the research file; members of formulary, purchasing, and device committees, where a payment and a vote can sit side by side; frequent speakers and consultants; and anyone who reports an ownership or investment interest.

Route errors into the window, not around it

A dispute over a physician's record belongs to the physician. CMS does not mediate, and the institution cannot file it for them. What a program can do is put the record in front of the physician while the window is open, prompt the dispute, and document the outcome either way. In practice almost none of this happens anywhere: formal disputes are measured in the hundreds against sixteen million published records a year, which is the subject of our dispute deficit page. A low dispute count is not clean data. It is unexamined data.

Why the manual version consumes staff

Everything above can be done by hand, and where it is done at all, it is: bulk-file pulls, physician-by-physician lookups, spreadsheets that go stale at the next refresh. That is skilled compliance time spent assembling data that already exists, before any judgment gets applied to it. The office pays twice, once in staff hours and once in the exposure that survives the gaps.

Where PayClear fits

PayClear gives each physician one free ledger of every industry payment, built from the public record and whatever CMS misses, with a channel to confirm or dispute each record while it can still be corrected. A physician sends their disclosure-ready report to any hospital they choose. For the institution, that turns an annual reconstruction project into receiving a record the physician has already reviewed.