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An Obituary

OpenPayments, Sunshine, Waste, Fraud and Abuse

   The stated premise of the CMS Open Payments system is, "Open Payments: Creating Public Transparency into Industry - Physician Financial Relationships." My own recent experience has lead me to question not just the implementation of this program but the validity of its design.

   My email disputing the accuracy of the records pertaining to me follows. It was sent April 27, 2018 to

To whom it may concern:

An undated letter arrived April 23, 2018 (the review period began April 1,
2018) from CMS stating "Drug or device companies have submitted records
indicating that you have received payments in 2017."  I don't know who or
who's algorithm made this stupid error.  The payments seem to have to
involved an interventional cardiologist in Indianapolis and were attributed
to me, a retired pediatrician who last inserted an intravascular catheter 
35 years ago.  There were 5 erroneous payment records and I have disputed
all of them on the Open Payments Web site.

1)
"Abbott Laboratories"|"Abbott Laboratories"|
"Please email TransparencyReporting@abbott.com, and provide a
preferred method of contact for us to reach you regarding disputes.
The government's system does not supply any means of contacting
individuals who dispute transactions."|
"2017"|
"452887445"|
"Attested"|
"General Payments"|
"10/05/2017"|
"14.94"|
...
"04/25/2018"|
"Initiated"|
"I have no relationship with this company.
 I have received no payments from this company."
2)
"Abbott Laboratories"| "Abbott Laboratories"|
"Please email TransparencyReporting@abbott.com, and provide a
preferred method of contact for us to reach you regarding disputes.
The government's system does not supply any means of contacting
individuals who dispute transactions."|
"2017"|
"450126291"|
"Attested"|
"Research Payments"|
"01/19/2017"|
"11656.00"|
...
"04/25/2018"|
"Initiated"|
"I have no relationship with this company.
 I have received no payments from this company."|
3)
"BOSTON SCIENTIFIC CORPORATION"|"Boston Scientific Corporation"|
"For assistance with the dispute resolution process, please contact:
Boston Scientific's HCP Reporting at BSCHCPSupport@bsci.com."|
"2016"|
"420834821"|
"Attested"|
"General Payments"|
"10/06/2016"|
"444.98"|
...
"04/25/2018"|
"Initiated"|
"I have no relationship with this company.
 I have received no payments from this company."|
4)
"BOSTON SCIENTIFIC CORPORATION"|"Boston Scientific Corporation"|
"For assistance with the dispute resolution process, please contact:
Boston Scientific's HCP Reporting at BSCHCPSupport@bsci.com."|
"2016"|
"420834819"|
"Attested"|
"General Payments"|
"10/06/2016"|
"346.49"|
...
"04/25/2018"|
"Initiated"|
"I have no relationship with this company.
 I have received no payments from this company."|
5)
"BOSTON SCIENTIFIC CORPORATION"|"Boston Scientific Corporation"|
"For assistance with the dispute resolution process, please contact:
Boston Scientific's HCP Reporting at BSCHCPSupport@bsci.com."|
"2016"|
"420834817"|
"Attested"|
"General Payments"|
"10/06/2016"|
"403.97"|
...
"04/25/2018"|
"Initiated"|
"I have no relationship with this company.
 I have received no payments from this company."|

Please fix this.

Additionally, the OpenPayments Web site is painful to work with.
I would refer you to access-board.gov for suggestions as to how 
make a Web site that is in the spirit of the ADA.  I would refer
you to coverage of how Alteryx, a marketing analytics firm, left an
unsecured database online that publicly exposed sensitive information
for about 123 million U.S. households -- to judge if your users 
should be forced into using Experian to gain access to this U.S.
government database. 

Finally, publishing the results of a hand audit of a few hundred
records where the payment address does not match the NPI address would
make this system seem a little less like cyber junk.

Sincerely,

John M. Miller M.D.
jmiller@ltu.edu
NPI 1063535821 (since 4-9-2007)
       

   In my previous experience Abbott Labs was a reliable provider of infant formulas that listened to its customers and clinicians. Hopefully the people who are working on this transparency database are not involved in quality control for anything that is used by patients. Note: John M. Miller at Methodist Hospital in Indianapolis is NOT NPI 1063535821!

From: openpaymentsnotifications@cms.hhs.gov
To: jmiller@ltu.edu
Subj: Open Payments Dispute Resolved No Change
May 8, 2018 11:25 AM

Abbott Laboratories has resolved your dispute (Dispute ID 101301)
regarding the following record with no change to the data:


- Record ID:  450126291
- Payment or Other Transfer of Value Date:  Thu Jan 19 00:00:00 EST 2017
- Payment Amount or Dollar Amount Invested:  $11,656.00
- Payment Category:  Research Payments

Abbott Laboratories specified the following reason(s) for regarding
the dispute as resolved with no changes to the data:

 Confirmed correctly reported to Indiana University and Principal
 Investigator John M. Miller NPI 1063535821. Questions or concerns
 please contact transparencyreporting@abbott.com.

You may view the updated Review and Dispute status of these records by
logging in to the Open Payments system, navigating to the "Review and
Dispute" tab, selecting the physician or teaching hospital and program
year, then searching for the records in the table at the bottom of the
Review and Dispute page.

If you disagree with this dispute resolution, you may dispute the record again.

If you have questions pertaining to this dispute, please contact
Abbott Laboratories directly. CMS is not involved in dispute
resolution.

If you have any questions or concerns, contact the Open Payments Help
Desk by email at openpayments@cms.hhs.gov or by telephone at
855-326-8366. For more information about the program, visit the Open
Payments website at https://www.cms.gov/openpayments.

Do not reply to this automatically generated email.

   At 5:50pm May 8, 2018 I have again disputed Record 450126291 and the new dispute number is 104547. It seems that Abbott Laboratories made no attempt to check that the NPI number of the cardiologist in Indianapolis was the correct one. Many years ago I was satisfied that the quality controls on their infant formulas were good. This current episode leaves me wondering.

   May 15, 2018 I have tried repeatedly to get these erroneous records fixed. The period for my input is now over and I have sent the following:

From: jmiller@ltu.edu
To: openpayments@cms.hhs.gov, TransparencyReporting@abbott.com, BSCHCPSupport@bsci.com
Subject: Open Payments records corrupted with wrong NPI
May 15, 2018 8:19 PM

Dear Sirs:

It should be clear to anyone that the 5 records on the Open Payments
system with my NPI are all ERRORS!

I have repeatedly used your Web site to dispute the records.  It seems
the next step is entirely yours to take to clean up your data before
presenting it to the public.  From your Web site documentation it is
equally clear that NPI is not an editable field and therefore you must
delete these records.  New accurate records can then be uploaded with
the NPI of the physician who actually received the payments -- again
this is not my problem.  It seems to me that if you are saying this
system is a benefit to patients then you should make some minimal
effort to clean up your database.  You need not bother to contact me
again -- the responsibility to fix the problem is entirely yours from
abysmally substandard editing of input.

Sincerely,

John M. Miller M.D.  1063535821  

John M. Miller M.D.

Revised May 15, 2018