Open Payments System Available for Data Submission

We are pleased to announce that the Open Payments System is now available for data submission.  Applicable manufacturers and group purchasing organizations (GPOs) (collectively referred to as reporting entities) may register and/or recertify and begin submitting Program Year 2023 data.  All data submission activities are completed within the Open Payments System.  To access the Open Payments System, you must be registered within the Centers for Medicare and Medicaid Services (CMS) Enterprise Portal.  If your organization has reportable Open Payments data, registration in the Open Payments system is required to submit data to CMS.  If your organization is already registered, please remember to recertify; yearly recertification is required for entities with reportable data.  The Open Payments system no longer accepts records for Program Years 2013 through 2017.  If you have not accessed your account in the last 180 days, you will need to call the Open Payments Help Desk at 1-855-326-8366 (TTY: 1-844-649-2766) to reactivate your account.

Program Year 2023 Data Submission Period

Reporting entities may begin data submission activities.

Program Year 2023 data submission is now open and will close on Sunday March 31, 2024.

In order for Program Year 2023 reporting to be considered timely, the data must be both submitted and attested by the reporting deadline.  Any records submitted or attested after the deadline are considered late and therefore noncompliant with program requirements.  Noncompliant records may result in civil monetary penalties.  CMS recommends completing the submission process as early as possible in the submission window to avoid potential slower system responses at the end of the submission window, as this will not constitute a valid mitigating circumstance for a late submission.

Data Collection Reminder: Teaching Hospital Context Field

The requirement for submitting additional context is now mandatory for teaching hospital records reported in Program Year2023.  This is a free form text field to help the hospital identify the payment in its internal tracking system to be able to verify it during the pre-publication review process.  This information can include payment reference number, check number, name of the hospital’s department to which the payment was made and/or the name of the point of contact within the hospital who signed for the payment.  Information provided in this field will not be included in the publicly released dataset and appropriate content is up to the discretion of the reporting entity.

All reporting entities should review their contact information.  The contact information should include at least two up-to-date points of contact in the organization.  This action should be taken every year during recertification.  It also must be kept current for at least two years following record submission, even if the reporting entity does not submit records for subsequent program years.

Contact information includes a mailing address, e-mail address, and names of the points of contact.  If your organization has incorrectly entered this information or if it is outdated, you may not receive crucial information about potentially inaccurate, untimely, or incomplete records.  Not receiving compliance notices due to out-of-date contact information is not a mitigating circumstance for failing to comply and any civil monetary penalties that may result.   Accurate contact information ensures that your organization will receive all important program and compliance related communications, and is required by program regulations.

Open Payments Resource Updates & System Enhancements

The Open Payments resources are updated to reflect the new reporting requirements and enhancements to the system.  The updated resources are available on the General Resources and Resources for Reporting Entities pages.  It is recommended that you have the most recent versions of the Open Payments resources, including but not limited to: Open Payments User Guide for Reporting Entities, Data Submission Mapping Document, Quick Reference Guides, and the Error Code Key document.  A list and details of the latest Open Payments System Enhancements are available in the System Enhancements Documents located on the Open Payments General Resources Page.

Questions - Contact the Live Help Desk

Submit questions to the Help Desk via e-mail at openpayments@cms.hhs.gov or by calling 1-855-326-8366 (TTY Line: 1-844-649-2766).  The Open Payments Help Desk is operating on extended hours from 8:30am – 7:30pm (ET) Monday through Friday, excluding federal holidays.  The Help Desk refers media inquiries to CMS Press Office for response.