The Centers for Medicare and Medicaid Services (CMS) has announced that Open Payments registration and detailed data submission for applicable manufacturers and group purchasing organizations (GPOs) will begin on June 1, 2014, and will be completed in two steps. CMS has released an instructions document to explain the steps in the process, which is available on the Open Payments website.
During Step 1, which will run from June 1 through June 30, 2014, authorized officials of applicable manufacturers and applicable GPOs will be required to complete the following tasks:
- Complete Open Payments registration for themselves and their reporting entity, and confirm the accuracy of the reporting entity's profile data submitted during Phase 1; and
- Delegate roles and responsibilities by nominating system users to fill specific user roles, such as the roles of submitter and attester.
In addition, the individual in the submitter role should "perform test file uploads and submit data files to validate the file structure and contents of the file," and "utilize the error report produced by the Open Payments system to fix data errors (if any) in submitted files." Once these tasks are completed, users may move on to Step 2.
During Step 2, which will run from June 9 through June 30, 2014, the system will permit submitters to perform final data submission, and attesters to attest to the accuracy of their submitted detailed 2013 data. Steps 1 and 2 must be completed by June 30, 2014.
In addition to providing instructions for Phase 2, CMS also announced that it has made additional updates to its data submission resources that applicable manufacturers and applicable GPOs will use to submit detailed data during Phase 2. The updated resources are available on CMS' Open Payments website in the "Data Submission and Attestation" section. Additionally, CMS has provided a full explanation of the changes made to these resources in its "Open Payments - Data Submission Document Change Summary: May/June 2014" document. This document is also available in the "Data Submission and Attestation" section.
Please note that for the 2013 reporting year, CMS will not enforce penalties for reporting non-compliance until after the close of Phase 2. Also 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.