Open Payments Data: Review of Accuracy, Precision, and Consistency in Reporting

WHY WE DID THIS STUDY

The Open Payments program promotes transparency by making available to the public the financial relationships that physicians and teaching hospitals have with applicable manufacturers and group purchasing organizations. Although these financial relationships may provide important opportunities to increase medical research and enhance medical knowledge, they also can raise concerns because of their potential to influence the decision-making of health care providers. The transparency of the Open Payments program reveals the nature and extent of these relationships and has the potential to discourage the development of inappropriate financial relationships. However, the program can benefit the public only if the data reported are complete and accurate.

HOW WE DID THIS STUDY

To determine the extent to which data reported were missing elements, or were inaccurate or inconsistent, we downloaded data for 2015 from the Open Payments website in June 2016. To determine the role of CMS in validating Open Payments data received from manufacturers and group purchasing organizations, we reviewed policies and procedures and other information that CMS provided regarding its oversight.

WHAT WE FOUND

Of 11.9 million records published on the Open Payments website for 2015, less than 1 percent were missing required data elements. Although the Open Payments data elements reported to CMS were complete overall, we did identify records that contained inaccurate, imprecise, or inconsistent information. These include records containing drug and device names that do not match the definitions of these data elements; national drug codes (NDCs) that were not found in multiple Food and Drug Administration databases or other drug information resources; and payment dates from a different reporting year. CMS did note that it has conducted outreach to address data concerns with manufacturers and group purchasing organizations. CMS also reported that it is still compiling a list of noncompliant manufacturers and group purchasing organizations for further investigation.

WHAT WE RECOMMEND

We recommend that CMS take a number of practical steps to improve the accuracy, precision, and consistency of the data to better help consumers use the information: (1) ensure that records contain all required data; (2) strengthen validation rules and revise data-element definitions so that actual drug and device names must be reported; (3) revise the definition of the device-name data element so that the information reported is required to be more specific; and (4) ensure that manufacturers and group purchasing organizations report valid NDCs for drugs. CMS concurred with all four of our recommendations.