Designing an Effective Open Payments Compliance Program in a Hospital Setting

You are tasked with designing an Open Payments compliance system at your hospital. Please address the following in your program:

• Do you have a certain threshold/dollar value that you consider to be too much? Why or why not? 
• Do you examine payments from some pharmaceutical companies more than others? Why or why not?
• Do you have physicians internally report open payments disclosures prior to CMS publishing the official data? Why or why not?
• What are the consequences for a Provider receiving what you characterize as too much? 
• Are there any specific specialties you are more worried about than others? For example, are you more worried about your pediatricians or surgeons? Why?
• Are you more worried about research payments, food/beverages, consulting/speaker fees, travel/entertainment or all equally? Why?
• Do you think the Open Payments database serves its intended purpose? How would you improve this program?
• Correctly refer to any laws or regulations and apply the to the scenario 

RUBRIC