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Important updates from the IU School of Medicine

July 31, 2014

Access and review individual information from the Sunshine Act registry -- deadline for disputes Aug. 27

The Physicians’ Payment Sunshine Act, the Open Payments program, was passed as a part of the Affordable Care Act and requires that all manufacturers of drugs, devices and biological and medical supplies covered by federal health care programs collect and track all financial relationships with physicians and teaching hospitals. 

The program is designed to create a national disclosure program that promotes transparency by publishing the financial relationships between the medical industry and healthcare providers (physicians and hospitals) on a publicly accessible website developed by the Centers for Medicare and Medicaid Services. The goal of this public website (available no later than Sept. 30, 2014) is to increase access to and knowledge about these financial relationships and to provide information to enable consumers to make informed decisions. 

The definitions and requirements used for reporting to Open Payments by manufacturers are significantly different than those used by institutions such as the IU School of Medicine to achieve compliance with the U.S. Public Health Service/National Institutes of Health Objectivity in Research/Financial Conflicts of Interest regulations. The information an institution posts to its website (or makes available upon request) to meet the requirements of the Financial Conflicts of Interest policy may be different than the information posted in Open Payments. 

These differences may result in confusion and concern in the public. Individual faculty are urged to be aware of the information posted on Open Payments and, if appropriate, seek to resolve differences with the Centers for Medicare and Medicaid Services.

The first of the Open Payments data is available for review (and dispute if necessary) by individuals and institutions listed in the database before the data is made publically available.

Physicians, teaching hospitals, and physician owners or investors will have received a general notification that the reported information is ready for review if the physician, teaching hospital, and physician owners or physician investors have previously registered with the Centers for Medicare and Medicaid Services. Physicians, teaching hospitals, and physician owners or physician investors are encouraged to register to allow for notification. Additionally, the centers have utilized a general online notification. The general online notification is available at the link below.  

Individuals and institutions have until Wednesday, Aug. 27, to dispute the accuracy of the Open Payments data. For more information on how to submit a dispute, visit this page

Specific instructions for how to access the information are found on this attached Centers for Medicare and Medicaid Services tips document created by Stanford University. In addition, this FAQ document answers some common questions that faculty may have about this process. 

For further information about the Sunshine Act and its impact on IU School of Medicine faculty physicians, contact Alex Djuricich, M.D., associate dean for continuing medical education, at adjurici@iu.edu.

Feedback sought on federal CME rule change

The Centers for Medicare and Medicaid Services recently proposed a major change to the February 2013 Final rule of the Physician Payment Sunshine Act.

The rule under consideration states that industry companies are excluded from reporting payments to accredited Continuing Medical Education event speakers provided the companies do not choose the speakers, or directly reimburse them.

The explanation from the Centers for Medicare and Medicaid Services in July 2014 states:

 "…we are proposing to delete the Continuing Education Exclusion in its entirety. Eliminating the exemption for payments to speakers at certain accredited or certifying continuing medical education events will create a more consistent reporting requirement, and will also be more consistent for consumers who will ultimately have access to the reported data." 

More information about this proposed change can be found at the websites of Norton Rose Fulbright and Faegre Backer Daniels.

This proposal does not affect the indirect payment rule, which does not require reporting in the case of indirect payments to organizations if the funder is not aware of the physicians receiving funding.

Alex Djuricich, M.D., associate professor of clinical pediatrics and medicine at the School of Medicine and chair of the communications committee for the Society for Academic CME, will be writing a formal response to Centers for Medicare and Medicaid Services on behalf of SACME.

Any faculty interested in contributing specific language for this response should contact Dr. Djuricich at adjurici@iu.edu.  

Vaccination deadline extended

The deadline for IUSM faculty, staff, students, fellows and residents considered employees at IU Health to receive a flu shot for the 2014-2015 Flu Season been extended from Nov. 14 to Nov. 21.

Flu vaccinations for these groups are mandatory. Individuals who wish to seek an exemption from this rule must submit application from Aug. 1 to Sept. 1. The exemption form will be available on pulse.iuhealth.org/flunews.

IU Health Employee Health Services -- Employee Occupational Health Services at some entities -- will offer vaccines to IU Health team members at various locations and times starting in August. More information on flu clinics will be available on pulse.iuhealth.org/flunews. Vaccine received through the IU Health clinics will be documented automatically. 

Starting in the fall, IUPUI faculty, staff and students will be able to obtain flu vaccine at Campus Health (Coleman Hall) or the IUPUI Campus Center Student Health.

University-wide compliance survey

Maintaining a culture of compliance at Indiana University allows us to serve our community and one another with integrity and respect.

In order to gauge the university's efforts, the IU Office of the Vice President and General Counsel needs insight on this University-wide endeavor. The office invites members of the IU community to participate in this three-minute survey. All responses are confidential and will help IU identify potential opportunities and concerns.   

Please access the Compliance Survey here. Your participation is appreciated. 

Any questions regarding the survey can be directed to comply@iu.edu.

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