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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 

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