According to the Centers for Medicare and Medicaid Services (CMS) Open Payments program website, February 18, 2014, marked the first day for registration and data submission for applicable manufacturers and applicable group purchasing organizations (GPOs). CMS is implementing a two-phased approach for this first reporting year. Phase 1, which will run through March 31, requires each entity's authorized official to register in CMS's Enterprise Identity Management system ("EIDM") and receive an EIDM user ID. The authorized official should be the entity’s executive level officer who can legally represent their organization, such as the Chief Executive Officer, Chief Financial Officer, Chief Compliance Officer, president, vice president, or other officer.

Next, registrants must complete a data file of specified 2013 Open Payments information and submit it to CMS via email to OPdata@cms.hhs.gov. The authorized official should use the sample template, available for download following registration in the EIDM, to submit data. In addition to general information regarding the registering entity, the form requires the following aggregate information regarding the applicable manufacturer's or applicable GPO's 2013 payments:

General payments and research payments aggregate data, including for each report:

  • The total aggregate amount of general payments and research payments the applicable manufacturer or applicable GPO has provided to covered recipients or physician owners/investors during the reporting period;
  • The total number of general payments and research payments made; and
  • The total number of covered recipients or physician owners/investors that were recipients of the general payments and research payments during the reporting period.

Ownership or investment interests aggregate data, including:

  • The total number of instances of physician ownership or investment interests during the reporting period.

Once CMS has received data submissions, the Open Payments Help Desk will review the file. The Help Desk will reply directly to the submitter, and will indicate whether the submitted data meets all requirements or if there is a problem. CMS will use the submitted data within the Open Payments system to create the registering entity's profile and prepare for Phase 2 data submission. Phase 2 will begin in May and will extend for at least 30 days, and will require entities to submit detailed 2013 payment data.

CMS has indicated that for the 2013 reporting year it will not enforce penalties for reporting non-compliance until after the close of Phase 2 registration and data submission. CMS has also indicated that it will announce additional information in the spring of 2014 regarding the review and correction phase, which is scheduled to begin on August 1, 2014. Please note that this phased approach to Open Payments registration and data submission is only for the 2013 reporting year, which includes data that was collected between August 1 and December 31, 2013.

On Tuesday, February 25, 2014, CMS will hold a webinar from 1:00 to 2:00 pm EDT to explain requirements for Open Payments Phase 1 registration and data submission. The webinar will be targeted to those primarily impacted by the registration and data submission requirements, including applicable manufacturers and GPOs, and the authorized official. Click here to register for the webinar.