Open Payments Submission Suggestions

In preparation for Program Year 2018 data submission and Program Year 2019 data collection, please note these suggestions that may be helpful for meeting the requirements for timely, accurate, and complete reporting to Open Payments.

These and other suggestions for reviewing data for submission are now featured in a “Submission Suggestions” document on the Open Payments resources page https://www.cms.gov/OpenPayments/Downloads/Open-Payments-Data-Submission-Suggestions.pdf.

Note: Open Payments Program Year Data Submission is scheduled from February 1, 2019 through March 31, 2019.

Review Content

Remember to verify your data for accuracy before finalizing your submission.

While submitted information may meet the requirements for data type, format, and field size, that does not necessarily mean that the contents of the fields are valid. Simple errors can impact the value of this data, such as: a misplaced dash or wrong number in a National Drug Code; a misspelling or abbreviation in a product name; or a zip code that is not valid or does not match the corresponding state.

Review your submission to ensure that the appropriate nature of payment categories have been selected. When deciding on a nature of payment category, it may be helpful to consider the following:

Choose the Nature of Payment category that most closely describes the reportable payment or transfer of value.
The context field can be used to include additional information. The information included in this context field is published on the Open Payments website.
The assumptions statement can be used to explain any methodologies used for selecting nature of payment categories. This statement is not published and is used to explain any methodologies or unusual submissions to CMS.

Submit Early

CMS recommends beginning the reporting process early in the submission window in order to allow time for addressing any errors or issues. Starting early helps to avoid longer upload times that may occur towards the end of the submission window when the system is being used most heavily. In order for data submission to be considered timely, both data submission and attestation must be completed by the end of the reporting window.

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Additional Resources

To view the “Open Payments Submission Suggestions” Resource Document, please see: https://www.cms.gov/OpenPayments/Downloads/Open-Payments-Data-Submission-Suggestions.pdf.

For additional information and resources such as the Open Payments User Guide, quick reference guides visit the Open Payments Resources page at https://www.cms.gov/OpenPayments/About/Resources.html

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Questions - Contact the Live Help Desk

Submit questions to the Help Desk via email at openpayments@cms.hhs.gov or by calling 1-855-326-8366 (TTY Line: 1-844-649-2766), Monday through Friday, from 9:00 a.m. to 5:00 p.m. (ET), excluding Federal holidays.

The Help Desk refers media inquiries to CMS’ Press Office for response. To report a possible reporting violation, please contact the Compliance Team at opcompliance@cms.hhs.gov.