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How to Document for the Open Payment Database Regulation

This article outlines a new workflow designed to ensure compliance with AB 1278, which requires providing patients with information about the Open Payments Database.

A flag for the Open Payments Database has been created for county use. The task is to notify clients with the following statement: “The Open Payments Database is a federal tool used to search payments made by drug and device companies to physicians and teaching hospitals. It can be found at openpaymentsdata.cms.gov.” A physician or surgeon must review this with the patient, who must then co-sign the service note as required. This task must be completed via any non-billable Service Note in SmartCare. For convenience, the “open payment database” keyphrase should be used.

This process applies to provider roles in SmartCare, including MDs and DOs (physicians and surgeons licensed by the Medical Board of California for allopathic physicians or the Osteopathic Medical Board of California for osteopathic physicians).

For more information, please visit: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB1278

If a client is enrolled in a program that is CMS certified, you will see a flag populate as soon as you open a client’s chart. This is to alert staff that this regulation must be reviewed and signed by the client. To document, follow steps below: 

  1. Click the Search icon, with the client open.
  2. In the Search Bar, type Services/Notes
  3. .Click to select Services/Note (Client).
  1. The Services/Notes List Page will open. Click the New icon.
  1. On the Service tab, click the dropdown menu and select the appropriate program. 
  2. Click the dropdown menu and select a non-billable procedure. This can be documented on any note type, but keep In mind the client will signing this document and will need to sign before the visit is over.
  3.  In the Service section, complete the rest of the required fields. 
  4. Click the Note tab. 
  1. Click in the appropriate textbox for the non-billable note you selected.
  2. Click the Menu icon in the upper-right hand corner.
  3. Click Favorite Phrases.
  1. The Use Key Phrases pop-out window will open on the left side. Click the Agency tab. 
  2. Click the drop down menu in the Category field and select CalMHSA Key Phrases.
  3. Scroll down to the bottom of the list. Click the Use hyperlink under the Open Payment Notice phrase. Close the pop-out window. 
  1. The phrase will be pasted into the textbox on your note. “I have informed my client about a notice that states “The Open Payments database is a federal tool used to search payments made by drug and device companies to physicians and teaching hospitals. It can be found at openpaymentsdata.cms.gov.”
  2. Click Sign. 
  3. Have the Client Sign the document. Instructions can be found here. 
  • Last Modified: March 24, 2025